Well-Designed Employer-Sponsored Wellness Programs Can Lead to a Healthier Workforce

T he United States is facing a health care crisis as costs continue to increase and our ranking of overall health remains poor compared to other industrialized countries. Poor health results not only in financial costs, but it impacts workforce productivity through absenteeism and presenteeism. In 2011, employers spent more than $8500 per active employee on health care coverage, 76% of the $11,176 total cost, with employees covering the balance.

To address this, many employers have turned to wellness programs, which seek to identify health risks for the employee and then provide programs to reduce those risks. Studies have shown that reducing health risks, the precursors to many of the chronic diseases now driving the increase in our health costs, can improve health status and workforce productivity while lowering the trend of future health costs.

A majority of these employer-based wellness programs use incentives to increase participation and engagement in the program. There are 2 basic types of incentives programs: those that are based on participation, and those that are based on outcomes such as stopping smoking, achieving weight loss, or reducing cholesterol levels. Although outcomes-based incentives programs are used by only a relatively small percentage of companies, the number of companies interested in implementing such an approach is growing.

Because of the concern for abuse or discrimination based on health status that might be possible using outcomes-based incentives, the US Department of Health and Human Services (HHS) has drafted some recommended rules for their implementation.

Last year a diverse group of stakeholders came together to see if they could reach consensus on guidelines for the use of outcomes-based incentives. This group included the Health Enhancement Research Organization, American College of Occupational and Environmental Medicine, American Cancer Society and American Cancer Society Cancer Action Network, American Diabetes Association, and American Heart Association. The Consensus group released their Guidance for a Reasonably Designed, Employer-Sponsored Wellness Program Using Outcomes-Based Incentives in the fall of 2012. Other groups including the Care Continuum Alliance, which represents 200 companies involved with population health management, engaged in discussions with the Consensus Group and also agreed with the recommendations.

The primary goal of the Consensus Group was to provide guidance to help employers implement programs that engage their workforce, improve employee health, and potentially reduce health care and other related costs over time while also protecting employees from discrimination and unaffordable coverage. We believe this guidance does just that.

As HHS considers its proposed rules for the use of outcomes-based incentives, we believe they should be guided by the Guidance for a Reasonably Designed, Employer-Sponsored Wellness Program Using Outcomes-Based Incentives.

The Consensus Guidance states that incentive design should be based on a reasonably designed wellness program, which is defined as a program that has a “reasonable chance of improving the health of or preventing disease in participating individuals.”

A reasonably designed wellness program is built on strategic planning and cultural support that includes working to create a culture of health within the organization. Such a wellness program includes assessment and screenings, behavior change interventions, and engagement methods through appropriate communications and incentives. It also has a rigorous evaluation mechanism with clear metrics of participation, member satisfaction, health outcomes, and financial results.

The Consensus Guidance also discusses issues of privacy, possible discrimination, HIPAA (Health Insurance Portability and Accountability Act) and GINA (Genetic Information Nondiscrimination Act) as they impact these programs, and the use of outcomes-based incentives. Each of these areas is further defined and discussed in the published consensus guidance.

As HHS considers their final rules we request they consider that programs that include incentives based on the achievement of health outcomes have the best chance of success when they are built upon a reasonably designed program, as defined in the Guidance for a Reasonably Designed, Employer-Sponsored Wellness Program Using Outcomes-Based Incentives. Appropriate definition of these rules would provide clarity to employers and their employees and allow employers to implement incentive-based outcomes as one more tool to assist their employees and their company in achieving a healthier, more productive workforce.