Employers have had to watch every step they take for fear that any misstep will result in a huge blow up. The ability for employers to effectively incentivize their employees to a healthier lifestyle really now lays in the knowledge that a third party vendor must administer the wellness plan if any variable incentives would be offered. And, as has been proven, the outcome-based incentives are what produce a positive change. Lifestyle improvements equal reduction in trend, increased presenteeism, employee health and wellbeing, and overall ROI.
If employer sponsored wellness programs are a minefield, then the latest rules have just detonated a few grenades. Outcomes-based wellness programs produce ROI. Plans with no incentives expect 20-30% total participation, which usually end up being the healthy employees. This kind of turnout gives smoking cessation tools or diabetic tools to the wrong people. It’s not the healthy that need a doctor but the sick.
Incentives can boost engagement to 60-70%, or 90-95% if well thought out. Higher participation provides ROI and early detection because the right tools are in the right hands. And to the employer, the wellness world finally makes sense. Their goal of providing employees with continued access to affordable health care coverage is accomplished for yet another year, right? Well not so fast…
Considering that incentives are vital to any ROI and positive movement, the government has chosen to “clarify” how incentives are engaged. Last week the EEOC (the government’s watch dogs around hiring and firing) have “clarified” targeted enforcements. See the full article here: http://www.hrmorning.com/wellness-incentives-fixed-firmly-in-eeocs-crosshairs-2-rules-to-watch/.
A year ago, new non-discrimination rules virtually eliminated HSA’s or FSA’s as vehicles for incentives. The affordability rules (otherwise known as the 9.5% rule) may eliminate premiums as an incentive because the penalty for non-compliance may overwhelm all ROI. ERISA/HIPAA/ and GINA have also added their “clarity”. But the penalties for non-compliance could cost more than any ROI.
Good news!!! Any incentives OUTSIDE and SUPPLEMENTAL to the base health plan remain protected. While BeniComp can help with any incentive (cash, premium, gift cards, deductible), BeniComp is the only organization with Department of Insurance filed/approved programs that provide a supplemental policy including non-taxable, compliant incentives.
In light of these ever changing rules, we would recommend the engagement of supplemental deductible incentives at the next renewal. We would also recommend a more established use of deductibles as incentives rather than any cash or premium gifts going forward. Effective ROI is the goal, but it must be coupled with a watchful eye on the compliance rules.
BeniComp remains a leader in the wellness field. Our complete wellness compliance paired with full clinical preventive outreach, and the only operating system in the market that includes smart phone apps for wellness tracking, makes BeniComp the first choice for your wellness needs. Call 866-222-0102 or check out our website at www.PulseOS.com for more information.
We appreciate your confidence in our counsel and will continue to keep you appraised on the latest wellness news.