Recently, I attended the 2015 RIMS Annual Conference & Exhibition, where Integro, a specialty insurance brokerage firm, was an exhibitor. I had the chance to question Scott Schanen, CEO of Dominium, Integro's national employee benefit consulting practice, about the current state of wellness programs, PPACA, private exchanges and the future of employee benefits.
The following is what transpired:
Q: Federal agencies seem to be really intent on making sure that wellness programs help keep employees not well. What do you think about the new guidelines?
A: Philosophically, we don't believe in restricting employers' ability to incent healthy behaviors. We believe employers should be able to require completion of biometric screenings or health risk questionnaires to participate in the plan. Employers aren't using this information to discriminate and they don't know the results on an individual level. Such data is used to make employees aware of their own health risk factors and help provide them with programs to help improve their health. This will lead to lower cost in the long run and allow employers to continue offering health benefits in the future.
Q: Are they clear enough?
A: In some ways the recent guidance from the EEOC, while more restrictive than PPACA, is still a relief. Employers now know the boundaries for incenting wellness programs to avoid potential future litigation. Prior to the EEOC's guidance, their stance wasn't clear. There is still some question as to how the EEOC guidance impacts incentives for spouses, if it does at all.
Q: Would they really affect any of Integro's clients?
A: Fortunately, there is little to no impact on many of Integro's clients. Most clients have been very conservative with their incentive programs and are below the 30 percent threshold, even when including participatory programs.
Q: How is employee counting going? Has anything turned out to be harder or easier than expected?
A: The process is still fairly new to employers and the variable hour reporting can be challenging. Our clients are looking to other third party service companies to provide the measurement and process. We expect this will continue into the foreseeable future.
