Wellness programs are evolving as analyses inform the industry on what’s working or not, especially as incentives raise the stakes on participation and employee health data are eyed for more extensive utilization and potential dissemination.
Among the top questions being raised in early 2016 are whether these programs are becoming less voluntary, and what the implications will be if companies start to publicly report their employees' aggregate health data.
Wellness programs are becoming more pervasive as an important part of healthcare strategy, and incentives – particularly financial – are also increasingly popular, said Steve Auerbach, CEO of Alegeus, which provides consumer directed healthcare solutions.
“However, despite having more information, tools, incentives, and programs available than ever before, these investments often fail to deliver the desired outcomes, and the market is still struggling to effectively engage healthcare consumers in a meaningful way,” he said. "It isn’t just about driving (or even forcing) more participation, but rather about facilitating smarter interactions that are targeted, timely, relevant, etc. to engage the consumer and influence their behavior.”
From the perspective of a benefits delivery provider, “We see growing complexity as employers use a variety of incentives to include premium variations and different plan designs (deductibles, coinsurance, etc.) for different levels of participation,” Eric Helman, chief strategy officer at Hodges Mace, added. “While we have seen these tactics raise participation, they can also contribute to employee dissatisfaction and administrative complexity when the benefits delivery platform is not up to the task.”
About the health data reporting initiative
Derek Yach, chair of the working group on health metrics and chief health officer of the Vitality Group, unveiled the initiative at the World Economic Forum in Davos, Switzerland in late January. It calls for businesses to publish employee wellness data to provide insight into the literal health of the company.
He described the impacts of sharing that data as aiding in the development of effective workplace programs, providing a window to investors on threats to growth, and giving a sense to consumers of how well a company looks after its people, which could play a role in purchasing decisions.
As for criticism that reporting could result in discrimination against employees perceived to be negatively impacting a company’s health report, or that aggregate reporting could still infringe on employee privacy, Yach said those issues have been addressed.
“Concerns about health data privacy and discrimination were explicitly discussed in the working group and incorporated in our recommendations,” he told Healthcare Dive. “Aggregate data and encouraging companies to report on change over time are some of the ways to ensure the incentives health reporting provide are conducive to improved population health.”
Legal protections abound, but don't prevent pushback
Employee Benefits attorney Sarah Millar, a partner and vice chair of the Employee Benefits & Executive Compensation Practice Group at Drinker Biddle, sees stringent legal protections in place for employees but warns that employers may still see resistance.
Regarding the perception wellness programs are becoming less voluntary, “Some people may feel that a higher incentive amount makes a program less voluntary,” Millar said. “But the law prohibits employers from making those incentives too high – 30% of the total cost of coverage (50% if the program includes a tobacco cessation feature) is what has been deemed an acceptable incentive amount.”
She added the current rules have further protections for employees. “If someone has a health condition making participation in a particular program medically inadvisable, the program must offer an alternative means of participation to allow that person to earn the incentive,” she said.
The same goes for the reporting of aggregate health data. “Again, there are many laws already in place that protect an employee’s individual health information, including HIPAA, the ADA, and GINA, as well as many state laws,” she says.
One concern she sees is while companies can take steps to ensure health data are not used to make internal employment-related decisions, "What about the employee who wants to change jobs? Will future employers use public information about a past employer to make hiring decisions?”
The remaining issue for reporting is that of acceptance. “There could be strong resistance from employees to having this type of information made public, even if it is published only in aggregate form,” Millar said. “We have already seen some companies step back from wellness programs due to pressure from employees. This could also happen with this type of public disclosure of the overall health of a company.”
From the wellness perspective
Sonic Boom Wellness CEO Danna Korn finds employers increasingly seeing the value of well-designed programs that drive a positive kind of engagement while they become more assertive about participation.
“A few employers have adopted a 'stick' approach, with penalties if you don’t play along with the wellness program… but more are finding that if the programs are well-designed, you don’t need a stick,” Korn said. “In fact, you really don’t need much in the way of carrots, either," she said. "With an effective program and communication strategy, social contagion is driving engagement and consistency, resulting in improved health habits for the long-term without the need to budget for hundreds of dollars in annual incentives per participant.”
Her opinion on reporting health data depends on what exactly would be collected and shared under the initiative, which is still under discussion.
“We’re big believers in rewarding effort as opposed to outcomes, so I can see a ton of value in publicizing, 'Our employees average 8,000 steps per day,' or 'Our average BMI has improved by XX% in the last year,' Korn said.
Publicizing such successes would reinforce positive behavior and serve as an example to others, she said. “But if these companies are just going to report that XX% of our population is obese, and XX% of our population smokes, it’s another story,” she said. This is because only the healthiest of companies would opt in, the figures would be likely to mirror state or national averages, and any self-reported data, such as smoking rates would be suspect, particularly when incentives are on the line.
The implications of reporting will depend on how it’s done, she concluded. “We have to make the distinction between shaming and encouraging,” she said.