We had a terrific turnout for our webinar this month, which addressed the current uncertainty of incentive rules. Our guest speaker, Barbara Zabawa, took us through the ins and outs of what’s legal and what’s recommended when considering financial incentives for wellness programs. She also provided great tips for how employers can further avoid ending up on the wrong side of the extremely vague laws governing wellness incentives. The key word legally is “voluntary.” What voluntary means is very much open to interpretation.
Three specific tips presented by Zabawa to more effectively position wellness programs as voluntary were:
- Understand your Population
Younger workers aren’t quite as concerned or sensitive about sharing private health information as older workers are. Lower-income workers are more likely to feel pushed into participating in wellness because it would be a financial burden to lose the incentive. So, take account of your population mix and tailor your strategy accordingly. Also consider your culture and experience. Is this your first year rolling out a program? Do you have a trusting culture? Have you successfully run incentive programs in the past without pushback from your workforce? All of these variables inform what might be right for you when it comes to designing incentives. - Be Careful with Messaging
Do you use words like “required” or “mandatory” when you talk about wellness, or do you use words such as “foundational” or “recommended”? Also, who is delivering messages regarding participation in wellness? If managers who have decision making authority over an employee’s job are the ones encouraging participation, it may feel less “voluntary” to that employee. Leaders should definitely model behavior by participating in the wellness program themselves, but the promotion of the program should come from those not directly influencing the employee’s daily responsibilities. - Make a Clear Contract
Clearly document what you’re doing, why you’re doing it, what information will be collected and who will see it. Fully inform your population so they can get comfortable knowing exactly how and when their personal information is being shared. Follow the structure of “Informed Consent” contracts offered by medical practices to guide your thinking here.
Did you miss the presentation? Want to dig deeper? Click here to access a recording of the session!
