The time has come. You’ve heard all about a Health Risk Assessment (if you haven’t, keep reading). The term “Biometric Screening” has been thrown around all over the place lately (you can find an overview of that here). You know it takes incentives to get employees excited enough to participate in a wellness program. And we’re sure you’ve considered the idea that maybe the insurance companies are using biometric data results to determine your rates at renewal. So let’s debunk some common misconceptions you may have regarding Health Risk Assessments and Biometric Screenings when administered by your insurance carrier.
What is a Health Risk Assessment?
A Health Risk Assessment consists of a series of questions designed to help you identify your potential health risks. Furthermore, it will help you establish attainable, measurable goals and the accompanying steps to modify or eliminate behaviors that may be keeping you from being as healthy as possible. Questions consist of family and medical history, physical activity, eating habits and other relevant lifestyle information that pertains to your overall health.
For the most accurate results and a basis of your overall health, it is encouraged to have results from a recent (within six months) Biometric Screening on hand while you take the Health Risk Assessment as you will be asked to input information such as blood pressure, HDL and LDL cholesterol, height and weight. Once complete, you will receive a summary that provides an action plan for improving your health.
It’s All About The Incentives
It is acceptable, and very common, for employers to provide rewards, or incentives, to employees for completing a Health Risk Assessment, a Biometric Screening or other wellness activities. Incentives are all solely at the discretion of the employer, but can range from small gift cards, cash prizes, depositing funds into a Health Savings Account (HSA) or Health Reimbursement Account and even a reduction of an employee’s portion of their premium.
In fact, it is even acceptable for an employer to reward an employee for meeting a particular health standard (ie BMI < 25, total cholesterol < 200, etc), given that the employer meets the HIPAA 5 nondiscrimination rules. The 5 requirements for wellness programs that tie a reward in with meeting a particular health standard are:
- 20% Limit on Reward: The total reward for all the plan’s wellness programs that require meeting a particular health standard must not exceed 20% of the cost of employee-only coverage under the plan (or the cost of family coverage if dependents also are eligible for the wellness program). Under PPACA, beginning in 2014, employers can increase this incentive under their group health plans from 20% to 30% of the total cost of premium.
- For example, if the total employee-only plan costs $400 per month, the incentive for meeting a particular health standard cannot exceed $80 per month for that employee.
- Reasonably Designed: The program must be reasonably designed to promote health or prevent disease. For this purpose, it must: have a reasonable chance of improving health or preventing disease, not be overly burdensome, not be a subterfuge for discriminating based on a health factor, and not be highly suspect in method.
- Annual Qualification: The program must give eligible individuals an opportunity to qualify for the reward at least once per year.
- Reasonable Alternative: The reward must be available to all similarly situated individuals. For this purpose, a reasonable alternative standard (or waiver of the original standard) must be made available to individuals for whom it is unreasonably difficult due to a medical condition to satisfy the original standard during that period (or for whom a health factor makes it unreasonably difficult or medically inadvisable to try to satisfy the original standard).
- Disclosure of Reasonable Alternative: In all plan materials describing the terms of the program, the availability of a reasonable alternative standard (or waiver of the original standard) is disclosed.
A wellness program is subject to the HIPAA nondiscrimination rules only if receiving the incentive is tied with meeting a particular health standard.
With that in mind, if a wellness program is not based on an individual meeting a particular health standard, then it does not have to satisfy the 5 HIPAA nondiscrimination regulations listed above, including the rule limiting the amount of the reward for health-contingent wellness programs to 20% of the cost of coverage.
For example, it is acceptable for an employer to offer a 50% premium discount for employee-only coverage for those who participate in a wellness program that consists of attending a monthly health seminar, providing healthier food choices in the workplace, paying for gym memberships or providing pedometers to encourage employee walking and exercise, to name a few examples.
What about completing a Health Risk Assessment or a Biometric Screening that is administered by your insurance carrier? Can an employer require employees to complete either one in order to enroll in the group health plan? Yes, provided that the health information is not used to deny, restrict, or delay eligibility or benefits, or to determine individual premiums.
Now on to perhaps the biggest question of all. Will results from a Health Risk Assessment or Biometric Screening be shared with the insurance company for underwriting purposes or even shared with my employer? No. All the personal identifying and health information that you submit when you take the Health Risk Assessment or complete a Biometric Screening, as well as the results, are fully protected by the HIPAA Privacy Rule. Insurance carriers are not permitted to use this information to increase your coverage costs, limit your coverage, or restrict you from any benefits or opportunities you would otherwise have.
Neither the insurance underwriters nor will your employer ever receive personally identifiable information about you that are tied to your results of a Health Risk Assessment or Biometric Screening. It is acceptable for the insurance carrier to share aggregate results with your employer, but individual employee answers are never shared. It is important to remember that your results will be combined with those of other respondents from your company and provided to your employer in a report that indicates potential health challenges employees may be facing. Your privacy will not be compromised in any way.
If your company is considering implementing a wellness program, we can assist in getting Health Risk Assessments and Biometric Screenings set-up for your employee population. We believe this is the best way to start. If you don’t know where you are, you won’t know how to get where you need to be.
Even if you still aren’t sure whether a wellness program is a right fit for your company or not, send us an email or give us a call. You might be surprised to know how little of a cost it is to provide a Health Risk Assessment and a Biometric Screening to your employee population or that some insurance carriers will even provide these to your company for free.