Wellness Incentive Guidelines
Wellness programs are now fairly ubiquitous, and many provide incentives or penalties for using or not using the program, or even for achieving or not achieving certain biometric goals. The federal reform law gave its blessing to these programs by authorizing fairly substantial incentives/penalties. Some have expressed concern about the effect on employees who are disabled or otherwise might have difficulty complying with a wellness effort. A group of provider and disease-focused health care organizations has produced a set of guidelines which they believe will help employers maximize the benefits 0f and avoid harms from wellness programs. (Joint Guidelines Article) In general the statement is supportive of wellness programs and their efforts to encourage employees and their family members to engage in healthier behaviors. Incentives are recognized as potentially being helpful in getting employees’ attention and beginning the process of change, but concern is also expressed about the potential downsides to adding costs fpr non-compliant employees.
Current rules allow a 20% cost of coverage incentive/penalty and the reform law raises it to 30%. People who might have trouble meeting the general wellness or health requirement must be given a reasonable alternative. The group believes a well-designed program includes elements that encourage a culture of healthy behaviors, a voluntary health risk assessment and/or biometric screening, behavior change interventions based on evidence, engagement tools such as communication and assessment and continual measurement and assessment of the effects of the wellness program. In regard to incentives, the group statement notes that there is inconsistent research about how to best design a penalty, as well as concerns about attaching incentives to meeting of specific biometric measures, for example, as opposed to mere participation in and completion of a wellness program. The statement provides a useful general background piece on wellness programs and incentives.