In November, the U.S. Department of Health and Human Services (HHS) issued a proposed rule governing wellness programs offered as part of employer-sponsored health plans for plan years beginning January 1, 2014. The proposed rule is aimed at boosting incentive for large employers to increase the health status of their employees since large employers will be continue to be regarded as discrete risk pools under the Patient Protection and Affordable Care Act, whereas small employers will be collectively treated as a single risk pool.
In addition to the traditional participatory wellness programs such as discounts on fitness club memberships, health assessments and seminars, the proposed rules create an enhanced incentive for employers to offer health contingent wellness programs. The contingency? Employees must adopt a lifestyle changes and health improvement plans designed to help them reach target biometric goals such reducing weight, body mass index (BMI), blood pressure, or cholesterol levels. If they hit the prescribed targets, the proposed rule would allow employers to reward the employee with a payout of up to 30 percent of the cost of the employee’s health coverage for the plan year, an increase over the current 20 percent permitted under rules adopted in 2006.
The rulemaking’s preamble suggests HHS believes the increase in the maximum reward is necessary to boost participation in contingent wellness programs. It cites a 2010 survey by NBGH and TowersWatson in which just four percent of responding employers reported offering financial incentives for maintaining a BMI within target levels. Only three percent did so for maintaining targets for blood pressure and cholesterol levels. Based on these numbers, increasing the maximum award level alone isn’t likely to produce a significant increase in the number of employers and employees participating in contingent wellness programs.
However, if such programs were joined with affording employees greater control over when and where they work, participation could increase substantially and employers would see a potentially large payoff in improved employee health status and reduced medical utilization. Schedule control eliminates the “I don’t have time” excuse for not engaging in health promoting behaviors such as regular exercise and getting sufficient amounts of sleep. If employers want employees to take responsibility for their health, they must give them the means to adopt healthy lifestyles and avoid the daily sedentary (and hardly health promoting) routine of commuting to and from and sitting in a centralized office. Plus they would likely enjoy the added bonus of crisper and more creative thinking and better ideas from employees getting plenty of sleep and exercise thanks to having more control over their work schedules.
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