Starting this year under the Patient Protection and Affordable Care Act, $200 million in incentive grants are available to some small employers that create comprehensive wellness programs. The grants are available through the Department of Health and Human Services and are accessible for up to five years, but eligible companies must meet size and program requirements.
To be qualified, businesses must have fewer than 100 employees working 25 hours or more a week, or no more than 25 full-time-equivalent employees. To be approved, companies may not have had workplace programs prior to March 23, 2010, the day health reform was signed into law. Program fundamentals
There are four key aspects that must be included in eligible comprehensive wellness programs:
• Health awareness activities, such as instruction, preventative health screenings and risk evaluations must be included.
• Participation is key, and organizations that want to take advantage of grant funds must strive to engage as many team members as possible in the wellness program’s offerings, possibly using tools that motivate staff to become involved.
• Wellness programs should provide counseling, seminars, online information and self-help resources that are focused on modifying unhealthy behaviors and lifestyle choices.
• Companies also need to provide support, such as policies and procedures that promote physical activity, improved mental health and healthy living choices.
Employers that institute wellness programs to share in grant funding must comply with all federal and state anti-discrimination laws. Wellness programs must be voluntary. Not only is requiring participation forbidden, but also, companies cannot penalize employers who choose not to participate. The option of participating, however, must be available to everyone, regardless of disability, and medical information obtained cannot be used to limit health insurance coverage or advancement opportunities. All medical records must be treated as confidential documents and maintained separate from personnel files.Participation vs. rewards
Wellness programs may be participatory or health-contingent, and a business may offer either or both. Participatory programs do not make rewards available to staff based upon the attainment of health-related goals. For organizations participatory programs, allowable incentives include fitness center reimbursement programs, rewarding associates for going to periodic health education seminars and diagnostic testing without establishing rewards due to test results. Health-contingent wellness programs establish health criteria and provide incentives for achieving goals. Targets might be developed for issues such as cholesterol levels, amounts of exercise or less use of tobacco products. Examples of rewards are discounts, reimbursements or the elimination of health insurance premiums or costs.
If the health-contingent wellness program is part of a group health plan, Health Insurance Portability and Accountability Act nondiscrimination regulations apply. The total reward is restricted to 20 percent of the entire expense of employee-only coverage under the group health plan. If any class of dependents is allowed to join, the 20 percent is figured from the cost of coverage for employee and dependents. Beginning Jan. 1, 2014, the percentage will increase to 30 percent under reform law, and the departments of Labor, Treasury and Health and Human Services are considering an increase to 50 percent. A health-contingent program must advance health or prevent disease and may not be excessively difficult. Those eligible for the program must be allowed to qualify for the prize at least yearly, and rewards must be available to all “similarly situated individuals,” according to the law. Thus, a waiver or reasonable alternative standard must be offered to employees who find the program measure unreasonably difficult or ill-advised due to a medical condition. The waiver or alternative standard must be stated in all plan materials explaining the wellness program.
Details about grant funding for wellness programs are available through the U.S. Department of Health & Human Services, www.hhs.gov.Lynne Haggerman, M.S., is president/owner of Lynne Haggerman & Associates LLC, a Springfield firm specializing in management training, retained search, outplacement and human resource consulting. She can be reached at firstname.lastname@example.org.