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![NoticeNoticeNoticeNotice
◦ The final rules require health-contingent wellness plans
to disclose, in all plan materials describing the terms of
a health-contingent wellness program: the availability of
a reasonable alternative standard (and, if applicable, the
possibility of a waiver), contact information for obtaining
the alternative, and a statement that recommendations
of the employee’s personal physician will be
accommodated. The following sample language is
provided, which differs from the proposed rules in that it
indicates that the plan will work with the individual’s
doctor:
“Your health plan is committed to helping you achieve your
best health. Rewards for participating in a wellness program
are available to all employees. If you think you might be
unable to meet a standard for a reward under this wellness
program, you might qualify for an opportunity to earn the
same reward by different means. Contact us at [insert
contact information] and we will work with you (and, if you
wish, with your doctor) to find a wellness program with the
same reward that is right for you in light of your health
status.”](https://image.slidesharecdn.com/goodhealthgreatwealth-effectiveemployeewellnessplandesign-180605173715/75/Good-Health-Great-Wealth-24-2048.jpg)
Good Health = Great Wealth
- 1. Presented by: Gavin Vitter,Director of Personnel Services and Operations Central Community School System American Association of School Personnel Administrators 75th Annual Conference - San Antonio, TX September 30 – October 4, 2013
- 3. Houston Chronicle, 2013 ◦A wellness program is any program implemented by an employer to improve the health of its labor force. http://smallbusiness.chron.com/employee-wellness-program-1349.html California State University at Fullerton, 2005 ◦ The Employee Wellness Program is centered around the promotion of physical activity and healthy lifestyle choices. http://hhd.fullerton.edu/ewp/ Federal Bureau of Investigation, 2011 ◦ A Strategy for Fighting the “Evil from Within.” http://www.fbi.gov/stats-services/publications/law-enforcement-bulletin/december-2011/the-employee-wellness-plan
- 4. Entrepreneur Magazine, 2013 ◦Servicesfocused on theServices focused on theServices focused on theServices focused on the promotion or maintenancepromotion or maintenancepromotion or maintenancepromotion or maintenance of good health rather thanof good health rather thanof good health rather thanof good health rather than the correction of poorthe correction of poorthe correction of poorthe correction of poor health.health.health.health. http://www.entrepreneur.com/encyclopedia/wellness-programs
- 5. Need to statea GoalGoalGoalGoal or Strategic Objective:Strategic Objective:Strategic Objective:Strategic Objective: ◦ To improve the health of employees in order to prevent or eliminate health risk factors and future chronic diseases. Shared Common Characteristics: ◦ Establish a supportive work environment to promote employee engagement ◦ Improve lifestyle behavior that reduces health risks: Ceasing tobacco use Encouraging exercise/fitness Improving Nutrition Reducing Stress ◦ Identify the most common and personally modifiable risk factors:
- 6. Obesity High Blood Pressure HighCholesterol Depression Smoking Lazy Lack of Sleep Time ◦ Encourage screenings and assessments Cancer Screenings Personal Health Assessments Flu Shots Annual Wellness visit to the doctor – It’s FREE!!! ◦ Use coaching and promote employee peer support Reduces health risks Enhances individual productivity quality of life ◦ Voluntary Participation
- 7. ◦ Use Incentives Money$$ Airline Tickets Paid Vacation Day Pick up the monthly premium Pay for a Health Club Membership Health Insurance carrier May have Wellness Program built-in and ready to go May have incentives Internet Portals Employee individual tracking Points and redeem at the “mall” Steven F. Cyboran and Sadhna Paralkar, M.D. © Sibson Consulting / The Segal Group
- 8. Information to makepeople aware of health risk factors and why it's important to reduce/eliminate those risk factors. Health-risk assessment questionnaire and biometric testing to help people identify if they have any health risk factors. Biometric testing often includes measurement of blood pressure, weight, body mass index, waist/hip ratio, glucose and cholesterol. Educational programs (e.g., weight-loss programs, exercise programs, tobacco-cessation coaching and/or stress-management counseling) with incentives to help people stay healthy and/or begin to reduce their health risks. Worksite/plan sponsor support to attain/maintain behavior change such as blood pressure monitors to check readings, medical plan payment for tobacco-cessation products and diet-education classes. Tracks improvement in health risk factors over time along with other improvements (e.g., attendance/sick time, short-term disability and Family and Medical Leave Act use, productivity, impact on workers' compensation claims. http://www.shrm.org/hrdisciplines/benefits/articles/pages/wellness-programs-in-brief.aspx
- 9. Every answer toa Human Resource questions is… IT DEPENDSIT DEPENDSIT DEPENDSIT DEPENDS
- 10. RAND Health’s 2013Workplace Wellness Programs Study - Sponsored by the U.S. Department of Labor and the U.S. Department of Health and Human Services, summarized: ◦ Wellness programs have a minimal impact on health care costs. ◦ Estimated it takes an average of five years for a new wellness program to become cost neutral. ◦ The Return on Investment (ROI) is not statistically significant. http://www.rand.org/pubs/research_reports/RR254.html#key-findings
- 11. It should benoted that RAND’s findings reflect the average results of a random sample of wellness programs—the good, the bad and the mediocre. What the study does not take into account is that every wellness program is unique. Although many fail because they are improperly designed or implemented, those that succeed generate substantial ROI, and often in less than five years. http://www.shrm.org/hrdisciplines/benefits/articles/pages/wellness-roi-design.aspx
- 12. A Harvard Universitystudy of 100 peer-reviewed journal articles, Workplace Wellness Programs CanWorkplace Wellness Programs CanWorkplace Wellness Programs CanWorkplace Wellness Programs Can Generate SavingsGenerate SavingsGenerate SavingsGenerate Savings, found that a properly designed wellness program can expect to yield an ROI of 3.27:1 on health care cost reductions and another 2.73:1 on absence and related costs after about three years. To calculate ROI, the amount saved as a result of a program (e.g., lower health care spending) is divided by the dollars spent on the program. The result is expressed as a ratio, with an ROI of 2.50:1 indicating a return of $2.50 for every $1 invested. http://content.healthaffairs.org/content/29/2/304.full.html
- 13. Larry S. Chapman,M.P.H., an expert on wellness programs conducted the MetaMetaMetaMeta----EvaluationEvaluationEvaluationEvaluation of Worksite Health Promotion Economic Returnof Worksite Health Promotion Economic Returnof Worksite Health Promotion Economic Returnof Worksite Health Promotion Economic Return Studies: 2012 UpdateStudies: 2012 UpdateStudies: 2012 UpdateStudies: 2012 Update, a meta-study of 56 peer-reviewed journal articles, the more recent studies documented ROI in the range of 6:1 compared to 3:1 in the older studies. He also discovered it generally takes three to five years for wellness programs to realize their full impact. http://www.ajhpcontents.com/action/showMultipleAbstracts?doi=10.4278/aj hp.26.4.tahp&href=/https/www.slideshare.net/toc/hepr/26/4&mailPageTitle=Table+of+Contents+for+ American+Journal+of+Health+Promotion:+Volume+26,+Issue+4+<br/>(Mar ch/April+2012)
- 14. Simply having ormaintaining a wellness program does not ensure effectiveness or positive ROI. Employers and employees must take ownership of the program. Employees must see that top management not only supports and encourages healthy lifestyle changes, but also participates; and in many cases LEADS the changes.
- 15. Strategic focus isimportant to program effectiveness ◦ Program leadership, a strategic health plan, and shared vision and collaboration among vendors correlates most with overall wellness effectiveness. Metrics matter ◦ Benefits of the wellness plan can be measured in terms of lower health care costs, turnover and absence. Establish a dedicated initiative leader and a wellness committee.
- 16. Develop a healthyenterprise strategy that is aligned with the organizational strategy. Inventory and assess the current state. Involve key stakeholders. Re-evaluate the many investments the organization males to become a healthier enterprise. Take steps to et employees to embrace the initiative. Create an effective workplace. Pay attention to dependents. Measure outcomes. http://www.sibson.com/publications/surveysandstudies/HealthyEnt.pdf
- 17. Develop and embracean organizational vision for health. Secure senior management commitment and participation. Address workplace policies and the work environment. Employ diagnostics, informatics and metrics. Set health goals and tailor program elements to meet them. Create a value-based plan design (using incentives to encourage participants to make high-value decisions). http://www.ihpm.org/pdf/EmployerHealthAssetManagementRoadmap.pdf
- 20. New types ofWellness Programs: ◦ Participatory Wellness ProgramsParticipatory Wellness ProgramsParticipatory Wellness ProgramsParticipatory Wellness Programs ◦ HealthHealthHealthHealth----Contingent Wellness ProgramsContingent Wellness ProgramsContingent Wellness ProgramsContingent Wellness Programs A participatory wellness program does not violate HIPAA’s nondiscrimination rules if participation is made available to all similarly situated individuals, regardless of health status. Participatory wellness programs are programs that do not provide a reward, or do not include any conditions for obtaining a reward that are based on satisfying a standard that is related to a health factor. The final rules confirm that rewarding employees for completing a health risk assessment, without any further action required by the employee, is a participatory program. Other examples include:
- 21. Reimbursing employees formembership in a fitness club; A diagnostic testing program that provides a reward for simply participating in the program; and Reimbursing or rewarding employees for simply participating in a smoking cessation program. The new rules subdivide health-contingent wellness plans into “activity“activity“activity“activity----only”only”only”only” and “outcome“outcome“outcome“outcome----based”based”based”based” wellness programs and explain how the five requirements apply to each type.
- 22. ActivityActivityActivityActivity----only wellness program”onlywellness program”only wellness program”only wellness program” means a health- contingent wellness program that requires an individual to perform or complete an activity related to a health factor in order to obtain a reward but does not require the individual to attain or maintain a specific health outcome. Examples include walking, diet, or exercise programs. “Outcome“Outcome“Outcome“Outcome----based wellness program”based wellness program”based wellness program”based wellness program” means a health- contingent wellness program that requires an individual to attain or maintain a specific health outcome (such as not smoking or attaining certain results on biometric screenings) in order to obtain a reward. Outcome-based wellness programs allow plans to conduct screenings and employ measurement techniques in order to target wellness programs effectively (e.g. individuals who use tobacco may be targeted to participate in a tobacco cessation program). If a measurement, test or screening is used as part of an initial standard and individuals who meet the standard are granted a reward, the program is outcome-based.
- 23. Frequency of Opportunityto QualifyFrequency of Opportunity to QualifyFrequency of Opportunity to QualifyFrequency of Opportunity to Qualify ◦ The final rules retain the requirement that all health- contingent wellness programs must give an individual the opportunity to qualify for the reward at least once per year. Size of RewardSize of RewardSize of RewardSize of Reward ◦ The final rules follow the proposed rules and increase the maximum permissible reward for all health- contingent wellness programs to 30% of the cost of coverage, but for programs designed to prevent or reduce tobacco use the maximum reward may be up to 50% of the cost of coverage.
- 24. NoticeNoticeNoticeNotice ◦ The finalrules require health-contingent wellness plans to disclose, in all plan materials describing the terms of a health-contingent wellness program: the availability of a reasonable alternative standard (and, if applicable, the possibility of a waiver), contact information for obtaining the alternative, and a statement that recommendations of the employee’s personal physician will be accommodated. The following sample language is provided, which differs from the proposed rules in that it indicates that the plan will work with the individual’s doctor: “Your health plan is committed to helping you achieve your best health. Rewards for participating in a wellness program are available to all employees. If you think you might be unable to meet a standard for a reward under this wellness program, you might qualify for an opportunity to earn the same reward by different means. Contact us at [insert contact information] and we will work with you (and, if you wish, with your doctor) to find a wellness program with the same reward that is right for you in light of your health status.”
- 25. Reasonable DesignReasonable DesignReasonableDesignReasonable Design ◦ This requirement is similar for both activity-only and outcome-based programs in that the program must have a reasonable chance of improving health of participating individuals, and must not be a subterfuge for discrimination. In order to meet this requirement, however, the final regulations require that an outcome-based program provide a reasonable alternative to any individual who does not meet the initial standard based on a measurement, test or screening.
- 26. Uniform AvailabilityUniform AvailabilityUniformAvailabilityUniform Availability ◦ The same, full reward must be available to all similarly situated individuals under all health contingent wellness programs, but this requirement is applied differently depending on what type of health contingent program you offer. In order for the full reward to be available, plans offering a premium discount must provide the discount for the entire year. If an individual doesn’t satisfy a standard until mid-year, the plan may provide a retroactive payment of the reward when the standard is satisfied or may decrease payments pro rata over the remainder of the year. The plan may not provide pro rata payment over the following year (a year after the year to which the reward corresponds). Health-contingent wellness programs are not considered to be uniformly available to all similarly situated individuals unless reasonable alternative standards are made available.
- 27. Thank you foryour attention and participation. Gavin Vitter Director of Personnel Services and Operations Central Community School System Office: 225-906-4147 Fax: 225-262-1989 Email: [email protected] [email protected]