Employee wellness plans and employee wellness programs

Before you begin laying out your Company Wellness Program you need to have a benchmark.  Attaining a thorough needs assessment is vital to the effectiveness of your wellness program for two reasons:  First it ensures that your Company Wellness Program activities will be targeted to meet your company’s specific needs so that outcomes are able to be achieved.  Secondly the needs assessment supports the information you will need to evaluate the effectiveness of your wellness program.

It is frequently tempting to hurry through the assessment – especially when time is limited or those with experience already have an idea of needs.  Do not give in to this temptation!  It is critical that you be aware of what your corporation needs are, what upper management expects, and what workers want as well as expect, before you establish a Workplace Wellness Program.  

Consider and collect data on:

• Employee Demographic Information
• Employee Health Risk Factors
• Medical Claims
• Injury Rates & Causes
• Workers’ Compensation Claims
• Short and Long Term Disability Claims
• Absenteeism
• Company Culture Audits
• Employee perceived needs and health risks
• Senior Management’s expectations or desired outcomes

There are many ways to evaluate this information.  Although some of data gathering process may be time consuming, remember that it is nonetheless essential to plan programs that target specific problems.  This information will be essential to set goals and objectives and for evaluating program effectiveness.  How else can you know if outcomes have been achieved?

Options to help gather the information:

• Confidential Health Risk Assessments (HRAs) with a Employer Group Summary Report
• Wellness Screenings such as blood lipids, Blood Pressure and blood glucose click here for additional information on wellness screenings.
• Employee Needs and Interest Surveys
• Suggestion boxes placed around the organization
• Focus Groups or hosting a luncheon meeting as a focus group
• Sending out a confidential email questionnaire
• Review records and databases including OSHA logs, first aid reports, insurance expenditures  

Once your needs assessment is complete, the Corporate Wellness Program Committee can review the results and start creating and prioritizing program options.  Creating ought to be based upon goals and identified outcomes, Step 4 of the seven step process!

Organizing an active Workplace Wellness Program Committee provides opportunities for both upper management and employee involvement in the program.  The Committee ought to be a team of staff members and managers who formally meet to plan activities to promote healthier employee lifestyles.

Typical Functions of a Employee Wellness Program Committee:

• Analyzing needs & interests
• Brainstorming program ideas
• Planning activities
• Implementing communication plans
• Promoting programs to co-workers
• Serving as champions of the Workplace Wellness Programs
• Assisting with evaluation  

Your Workplace Wellness Program Committee should be representative of all echelons of the corporation.  Consider all sections of the workforce – multiple sites, shift employees, diversity (race, gender, ethnicity), and departments.   It’s also important to consider who will chair or co-chair the Workplace Wellness Program Committee and whether or not there are the finances to support a Workplace Wellness Program manager or occupational health consultant, even on a part-time or contractual basis.  Click here for more information on the benefits of a health consultant.  

Depending on your corporation size and resources, if you already have a corporation Safety Committee you might want to think about making it the Safety & Workplace Health Promotion Program Committee.  You are able to request volunteers or invite employees to participate.  

The number of Corporate Wellness Program Committee participants is dependent upon the size of your business; however, you need sufficient participants to get the work done and yet not too many to keep it manageable, usually at least 4 participants and maximum of 12 to 15 participants.  It’s valuable to include skeptics of wellness as well and not just those employees already living healthy lifestyles.  

Depending on your workplace, consider representatives from the following areas:

• Employee representatives from a cross section of different departments,
• Upper Management
• Health and safety professional(s),
• Human resources consultant(s),
• Employee benefits representative or someone from finance,
• Your EAP provider (if applicable), Click here for more information on EAPs
• Occupational health employee (if applicable).

Establish a strong Corporate Wellness Program Committee!  The Corporate Wellness Program Committee must meet often with a planned agenda and action items.  Effective Wellness Committees have a shared mission, vision and goals.  Members need to believe that their participation is worthwhile and appreciated, that their work is valuable, benefits the organization and co-staff members, and they are appreciated for their contributions. Refer to the NC Workplace Programs section for examples of what other employers have implemented.

As with any program, the two critical elements for the effectiveness of your wellness program are senior staff backing & employee involvement.  Senior Leadership determines the vision and supports the resources from which action plans flow.  Genuine backing from senior personnel also brings credibility to the wellness initiative.  It is important that senior staff be visible supporters and role models for your Workplace Health Promotion Program.

employees need to be involved on several levels so that they feel ownership of the wellness program.  Employees are the program stakeholders!  All employees should have an opportunity to support input and feedback through needs & interest surveys and program assessment tools.  The information gathered should be used to plan programs that target those needs and interests to ensure participation, buy-in, and reinforcement.

There are several methods to identify employee needs and interests such as:

• Having Employee Focus Groups
• Discussing Wellness Interests During Department gatherings
• Distributing and Summarizing a Needs & Interest Survey
• (Including|Allowing for|Making sure to include} a Time to Give Opinions on Each Evaluation Tool  

Any one or combination of several techniques will ensure that the wellness program meets what staff members want.

Step 3 supplies additional information on determining wellness program needs.  But first, instituting a Worksite Health Promotion Program Committee can help you involve upper management & workers, determine need, and plan your wellness program.

A key to a efficacious Worksite Health Promotion Program requires management responsibility and employee participation.

Workplace Health Promotion Program Step 2: Form a Workplace Health Promotion Program Committee

An active Employee Wellness Program Committee sees to employee participation, supplies buy-in, management reinforcement, and maintains a crew that is prepared to take action to launch wellness programs.

Worksite Wellness Program Step 3: Gather Data to Determine Key Needs and Expectations

The next essential component is to base the Workplace Health Promotion Program on the needs and interests of your organization and its workers.

Employee Wellness Program Step 4: Set Goals and Objectives

Goals and objectives are the road maps to guide you where your program needs to go.   These constitute the foundation for planning and evaluating activities to see to it that your wellness program will meet your special needs.

Worksite Wellness Program Step 5: Design a Detailed Action Plan

There is no such thing as over-planning!  The best of intentions can get lost, overstepped, or forgotten in the absence ofadequate planning, and then it would be all for naught.

Worksite Wellness Program Step 6: Choose and Begin a Plan

Once you have the needs assessment information, a Corporate Health Promotion Program Committee, objectives and goals it’s now time to put your plan into action!

Workplace Wellness Program Step 7: Oversee and Evaluate Your Workplace Wellness Program

Evaluation is an important step to keep a program focused, as well as to guarantee that the program is reaching its goals and objectives or achieving favorable results.

In Summary

These Seven Steps outline considerations for a inclusive approach to designing and launching an effective wellness program.  Would you be able to enable components of wellness activities without following these steps?  Absolutely, but you may not have the sustainability or ability to obtain desired outcomes.  Following the Seven Steps does not have to be confusing or burdensome.  A very simple approach can achieve a successful wellness program!

Therefore, to ensure a successful wellness program remember the key components as you plan your program or improve your current program:

• Upper Management Support & Employee Involvement
• Active Worksite Wellness Program Committee
• Employee Wellness Program is Based on Employee Needs & Interests
• Workplace Health Promotion Program Goals and Objectives are Determined
• Detailed Worksite Wellness Program Action Plan Based on Resources & Budget
• Company Wellness Program Implementation & Internal Marketing
• Evaluation of Workplace Health Promotion Program Outcomes

The program design options hinge upon the goals/objectives and desired outcomes of your program.  If your goal is to help workers make a change behavior, cut risk factors, or save health care dollars then your wellness program would be designed to accomplish those outcomes and a budget would be crucial to support that design.  

Wellness program design options vary, depending on desired outcomes and budgets.  Each level has advantages and disadvantages.  The intentions or results are quite different, are not interchangeable in terms of obtaining the same results, and therefore ought not be confused.  For example, scheduling activities such as an employee health & wellness fair or lunchtime education sessions, or having pamphlets available do not usually result in behavior change, but may expand awareness on a topic.  If the goal is behavior change then a different design is required, such as Lifestyle/Behavior Change Programs and Company Support.  The outline below describes the wellness design levels with a brief explanation.

Awareness Programs:  At this level a business makes health information available and accessible to staff members.  This type of program can include brochures on a variety of issues, wellness articles in newsletters, bulletin board displays, e-mail health messages, etc.   Also, most health & wellness fairs are designed as awareness programs with vendors offering information and offering health screenings to staff members.  

Awareness programs are inexpensive and do not require extensive employee or business time commitments.  However, these programs do not usually result in behavior modification.  Improving awareness isn’t usually enough to generate lifestyle changes for most individuals, unless used to arouse workers to register for a program being available at the business or area on the topic.  An example of this would be offering information on the dangerous effects of smoking and inviting workers who use tobacco to register for a smoking cessation class.

Education Programs:  Educational programs frequently support more information on a topic and are able to also provide time for questions & answers, but are similar to awareness programs.  An example is lunch-n-learn sessions on a health related topic.  These cost the organization a modest amount more than awareness programs; however, they are still inexpensive and do not require a great deal of time for planning or attending a session.  Again, expanding awareness and providing information may not lead to the desired behavior modification unless ongoing support or rewards and incentives are also planned.

Lifestyle/Behavior Change Programs:  These programs are designed as 4 to 12 weekly sessions or classes to support wellbeing and health education, address barriers and support opportunities to practice the desired skills.  Behavior change programs therefore require additional corporation resources, cost more, and also require additional employee responsibility, time and effort.  The results are frequently the desired beneficial lifestyle change, which if sustained can lead to potential cost savings.  

Examples include smoking cessation classes, weight loss and weight management meetings, or an ongoing fitness program.

Environmental and Business Support:  Environmental support is frequently considered the highest and most valuable level to include when designing your wellness program in order to support and maintain healthy behaviors.  These types of design options include policy changes such as:

• Creating a smoke-free workplace
• Designating a walking path,
• Establishing worksite fitness centers,
• Ensuring healthy vending machines choices,
• Offering healthy meal choices in the cafeteria, and/or
• Organizing flex-time policies.  

Other examples include subsidizing healthy vending machines or cafeteria choices; reimbursing fitness center or weight loss and weight management program memberships; or offering insurance incentives/rewards for healthy behaviors.

Ideally, the wellness program design would include some of all of these options.  The more integrated the approach, the more efficacious the outcome will be.  By way of example, a organization can have tobacco cessation information available; can schedule a one hour awareness session on the harmful effects of smoking and how to quit; can enable an worksite tobacco cessation program, supply self quit smoking kits, or support staff members to catch a neighborhood program; and/or on an environmental reinforcement level can establish a tobacco-free workplace and grounds, offer lower healthcare insurance for non-smokers, or provide pharmacological quit smoking aids for free.

Employee Wellness Program: Components for Success

There are many key parts that have to be considered to see to the success of your Corporate Wellness Program or Corporate Wellness Program.  These include:  

• Senior Management Support & Employee Involvement
• Active Workplace Health Promotion Program Committee
• Program is Based on Employee Needs & Interests
• Goals and Objectives are Established
• Detailed Action Plan Based on Resources & Budget
• Program Implementation & Internal Marketing
• Evaluation of Outcomes and Program

Major advantages of healthy workers include:

• Decreased Health Care expenses
• Reduced Injuries
• Reduced Rates of Absenteeism
• Boosted Morale and Loyalty
• Higher Productivity
• Lowered Use of Health Care Benefits
• Reduced Workers’ Comp/Disability
• Positive Perception in Community
• Lowered Turnover
• Better recruitment for competent employees

What is NOT Having a Corporate Health Promotion Program Costing Your Company?  

Let us look at the health risk factors that are contributing to chronic diseases for adults:

• 59 percent of American citizens are overweight or obese
• More than 60 percent of American adults do not exercise regularly
• Greater than 75 percent of American adults do not consume the minimum recommendations for fruits and vegetables
• Heart disease is the leading common cause of death and the leading cause of death in smokers
• 26 percent of workers reported they were often or very often burned out or stressed by their job  

Health Care costs are Growing:  Health Care expenditures are at a record high of $1.7 trillion with no signs of leveling out, let alone going down.  The average cost of yearly medical spending is over $5,000 per person and with dependents almost $10,000.  Recent data shows that medical related costs now cost North Carolina businesses thousands of dollars per employee, each year.

Most Illnesses Can Be Avoided:  Although it sounds unrealistic, experts indicate that avoidable illness makes up 60 percent – 70 percent of the entire burden of illness in the U.S..   In North Carolina, it is estimated that more than 53 percent of all deaths are avoidable, and that 2/3 of all avoidable deaths are due to tobacco use, a sedentary lifestyle, and poor nutrition.

Stress Levels are On the Rise:  As business resources dwindle and employers adopt cheaper work practices, the effects of absenteeism and lost productivity have a more powerful influence.  In a current national poll, 78% of American citizens described their jobs as stressful, and the majority felt that stress levels have become worse over The last decade.  Moreover, high levels of business stress have the potential to adversely affect a business by increasing injuries, absenteeism, and healthcare costs while decreasing productivity.  Simple solutions such as stress management education, flexible work schedules, quality social interaction, and increased participation in business decision-making have the potential to better stress levels in the workplace.

What is the Initial Cost and Time Investment for a Company Wellness Program?

The expenditure is dependent upon the type of Worksite Health Promotion Program implemented.  There are several options to reward employee health with pros and cons of each.  The program design is dependent upon the objectives and goals of the wellness program, the company resources, and the area resources available.  

Improving dietary practices, building physical activity levels, managing stress or discussing work life balance concerns, and decreasing/eliminating tobacco use, are primary strategies for preventing many of the most common preventable chronic diseases. The possibilities of how your organization deals with these concerns are endless and can range from building employee awareness, which may include purchasing a few handouts on a variety of topics, and quantifying walking distances around your facility, to instituting organization reinforcement such as funding a full-time occupational health consultant or building an worksite fitness center.  

When well-planned and based on your goals, any of these programs are able to help you succeed.  Refer below to Employee Health Promotion Program Design Options for additional ideas.

A Company Wellness Program is a comprehensive program to help and support workers in instituting healthier lifestyles.  This might possibly include rising employee awareness on health subject matters, scheduling behavior modification programs, and/or instituting company policies that support health-related objectives.  Programs and policies that encourage increased physical exercise, tobacco use prevention and cessation, and healthy diet selections are a few examples.  

Dimensions of Wellness

Wellness is more than physical fitness.  In addition to physical fitness, the ranges of ideal health include:

   • Spiritual Wellness,
   • Emotional Dimension of Wellness,
   • Social Dimension of Wellness,
   • Intellectual Dimension of Wellness

These dimensions are frequently illustrated as a “life wheel” with examples of health dimensions that include fitness, nutrition, purpose in life, financial organization, social connections & backing systems, stress management, mind-body health, career planning and continued learning.   The key behind individual health is keeping the “life wheel” in balance.  A comprehensive workplace wellness program addresses most, if not all, of these dimensions.

Why Company Wellness Programs?

workers spend much time on the job, and the bottom line is that our traditional work-week is increasing.  In fact, the typical American now is at work about 47 hours a week.  Additionally, technologies such as modems, laptop computers, cell phones, voice and email have confused the line between life and work.  These realities cut down on the amount of time that the average worker is able to devote to wellbeing and health pursuits, and yet workers are predicted to be top of their game when at work.

A current study conducted by the American Association of Occupational Health Nurses found that workplace wellness or Corporate Health Promotion Programs are efficacious in assisting workers to make positive health changes due to several factors such as convenience, environmental backing, and co-worker or social acceptance.  

What’s the Association between Wellness and the Workplace?

Programs and policies that encourage healthy lifestyles are able to make a tremendous difference on employee wellness AND have an impact on the company’s bottom line.  Studies have shown that for each dollar invested by employers in Company Health Promotion Programs/wellness programs, there were savings ranging from $1.49 to $4.91 with a median savings of $3.14*.  In company vocabulary, that’s more than a 3:1 minimum ROI – a number that is hard to overlook, and a best practice that ought to warrant serious consideration from employers.  In fact, a Company Health Promotion Program literature review published in Health Promotion Practitioner Journal observed:

   • 19 studies observed a 28.3 percent decrease in sick time
   • 16 studies demonstrated a 5.6:1 return on investment
   • 23 showed a 26.1 percent decrease in health care costs
   • 4 found a 30 percent decline in direct healthcare and workers’ compensation claims

There is little doubt that a accross the board wellness program designed to meet a employer’s specific needs can save money by lowering absenteeism, reducing medical care costs, reducing employee turnover, and building work rate.

• The U.S. Department of Health & Human Services, 2003

After cost, poor employee engagement and inadequate communications and support are listed as the greatest challenges for organizations administering any health benefi t program.22

By law, employers are required to explain any benefits or explicit conditions of employment to all workers – this is called “due process,” and it usually takes the form of a packet of information that new workers are asked to review and sign during orientation or, in the case of existing workers, a brief communication during open enrollment periods.

Organizations that only participate in the minimally needed due process communication of a Workplace Health Promotion Program, however, do a disservice to the initiative and the business.

Opinions about Medical Care in organizations represent one of the largest disconnects between management and staff members. In discussing the need for savings, most organizations (70 percent) believe their company effectively communicates about increasing Medical Care costs, while only 34 percent of staff members feel increasing Medical Care costs influence their business’ ability to succeed.23 When it comes to behaviors, 74 percent of organizations believe their staff members should be held largely accountable for improving, managing and maintaining health, yet only 4 percent of organizations think that staff members participate in these activities.

Under the proposed rules, the four requirements to be a bona fide Worksite Wellness Program are:

- The total reward that may be given to an individual is limited. The departments invited comments on the appropriate level of the reward, suggesting that a limit of 10% to twenty% of the total cost of employee-only coverage may be appropriate.
- The program must be reasonably designed to promote good health or prevent disease for people in the program.
- The reward must be available to all similarly situated people. More specifically, the program must allow any individual for whom it is unreasonably diffi cult due to a health care condition to meet the Company Health Promotion Program standard (or for whom it is medically inadvisable to attempt to meet the Company Health Promotion Program standard) an opportunity to satisfy a reasonable alternative standard.
- All plan materials describing the terms of the program must disclose the availability of a reasonable alternative standard.
Source: U.S. Department of Labor Employee Benefits Security Administration

As Northwestern Memorial’s Kathryn Krivy says, “The most fundamental failure in any Company Health Promotion Program is not communicating. You need to tell people what you’re doing and why you’re doing it. You have to get employees engaged and teach them of what’s going on.”

A properly started Employee Health Promotion Program is designed to save a business more money with greater participation. However, a business must match its focus on program design with an equally strategic investment in efforts to engage staff members in the initiatives.

Lay out your case – Despite widespread recognition of rising Healthcare costs, workers remain skeptical that the concern affects employer operations. In fact, only 53% of workers even believe what their employer communicates about the subject.24 Organizations need to be more candid and forthcoming about the amount they spend on Healthcare and how that relates to larger budgetary constraints and potential investments.

Says Motorola’s Saenz: “We share with staff members that we have been able to maintain Motorola’s Healthcare spend trend below national average over the past decade due to their participation in our various Employee Wellness Programs. This transparency is necessary to keep reminding people the reasons for our actions.”

An effective strategy is to focus on the cost savings and overriding health benefi ts to the employee and not the organization. By personalizing the information in this way, it creates a win-win scenario rather than presenting the program as a sacrifi ce on the part of the employee. Information ought to be presented through multiple channels, constructed in a way that makes sense to all levels of staff members, and offered to staff members, dependents and retirees.

Make it your own – Every Employee Wellness Program will be different, and must reflect the culture of a organization. While program areas will be determined by analyzing employee health risks, the actual offerings must be shaped by the nature of the organization. Younger, more active employee communities may be attracted by different programs than an older or technicaloriented employee. Additionally, a global organization with mobile employees will have different needs than a organization with one central location.

As noted earlier regarding PepsiCo’s HealthRoads, one strategy is for employers to brand their Worksite Health Promotion Programs. Union Pacifi c Railroad (HealthTracks), General Motors (LifeSteps) and Caterpillar (Healthy Balance) all adopted this approach to help create recognition and a larger meaning around their efforts. Having a branded program helps employees and other stakeholders see the larger objectives and goals of the Worksite Health Promotion Program, rather than focusing on isolated offerings.

Say it loud, say it proud – As a potential cost-saving plan, Worksite Health Promotion Programs should be given the same executive backing and internal responsibility as any comparable company effort. Corporations should not approach wellness as simply a preventive, financially-motivated program, but rather as an opportunity for the company to distinguish itself and become more competitive.

Jeffrey Treem, analyst, Edelman Change and Employee Program Engagement Group, says that effective communication about Workplace Wellness Programs should be integrated into existing corporation communication channels and vehicles. “This includes executive communication to external stakeholders,” he notes, “because this sends a powerful message back to workers about the priority of the programs. Workplace Wellness Programs should not be treated as merely an additional employee perk, but rather an innovative and strategic effort to lower costs and create a healthier work environment.” Talk among yourselves – The most powerful champions of any Workplace Wellness Program will be the participants.

Companies must discover ways to facilitate discussions about the program among workers. This could take the form of support groups, interactive media and the sharing of success stories.

Still, since Workplace Health Promotion Programs touch on potentially private health problems, it is important communication remains positive and inclusive, while not pressuring employees. Discussion of wellness problems ought to be voluntary, though businesses may consider providing incentives for those willing to contribute. Motivation and information from peers is likely to carry more credibility and significance than messages from management.

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Even in an at-will employment environment, people are still guarded from discrimination (including wrongful termination) by virtue of belonging to a protected class. Before beginning a Employee Wellness Program, employers need to be cognizant of the relevant legal restrictions and the potential affects these measures can have on benefi ts and employee behavior programs.

Title VII of the Civil Rights Act of 1964 – Prohibits employment discrimination based on race, color, religion, sex or national origin.

This means that standards and offerings need to be applied equally (or possibly proportionally) to all protected classes. In other words, if a company is offering access to fitness centers, it should ensure that men and women have equal access to facilities. Businesses should also consider whether individuals who may live in areas heavily populated by one race, religion or ethnicity also have access to facilities and programs. The easiest way to address this concern is to support onsite Company Health Promotion Programs whenever possible. This not only ensures equal access, but according to Northwestern Memorial’s Krivy, also boosts participation.

Businesses must also be aware that particular health problems may disproportionately affect protected classes. Health Risk Assessments and any incentives/rewards put in place may really should be customized to account for non-lifestyle related differences.

The Equal Pay Act of 1963 (EPA) – Protects men and women who perform substantially equal work in the same establishment from sex-based wage discrimination. Benefits, incentives and rewards and programs need to be applied equally to men and women. A business cannot set a weight goal for men and not for women, although a business can set health parameters by job function. The Age Discrimination in Employment Act of 1967 (ADEA) – Protects people who are 40 years of age or older from discrimination based on age.

Policies not only need to be available to people of all ages, but program objectives and goals, restrictions and incentives/rewards need to be designed with age appropriateness. While older staff members (or retirees and dependents) may inherently pose a higher health risk, their conduct must be assessed in terms of demographically appropriate measures.

Title I and Title V of the Americans with Disabilities Act of 1990 (ADA) – Prohibits employment discrimination against qualified people with disabilities in the private sector, and in state and local governments. Similar to other workplace offerings, any Worksite Wellness Programs, such as a fitness center or health clinic, would have to make reasonable accommodations for staff members with disabilities.

One area of uncertainty is whether very overweight staff members qualify as disabled. The problem is complicated because obesity is caused by several factors (genetics, environment, behavior), some of which may be out of the employee’s control. Generally, for staff members to qualify for disability based on obesity, the condition must signifi cantly impair their physical or mental ability to perform their job. This determination would need to be made by a qualifi ed physician. Although this label may affect the types of incentives and program requirements available, it likely would not affect the central implementation of behavioral-focused initiatives.

Civil Rights Act of 1991 – Provides monetary damages in cases of intentional employment discrimination.

This legislation permits people to sue organizations for improper treatment. Compensation can be in the form of actual damages such as lost or expected wages, compensatory damages for a postion that causes public embarrassment, or even punitive damages meant to send a message to a organization for egregious or habitual violations.

While these laws govern all organization activities, there are even more stringent restrictions with regard to Medical Care problems. Most policies, communications and data collection regarding employee health are governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Under HIPAA corporations cannot deny eligibility for benefits or charge a higher premium on the basis of:

• Health status
• Medical condition (including both physical and mental ailments)
• Claims experience
• Receipt of medical care
• Health history
• Genetic information
• Evidence of insurability (includes activities such as riding a motorcycle, skiing, snowmobiling and other similar pursuits)
• Disability

Nevertheless, because wellness programs may not include healthcare treatment or be insurance related, and may instead be confined to behavioral initiatives, HIPAA’s nondiscrimination provisions do not completely apply. To address this, in 2001 the American Department of Labor, the Internal Revenue Service and the American Department of Health and Human Services jointly issued a proposed regulation to help clarify the lawful provisions of a “bona fi de Wellness Program” in the context of HIPAA’s existing language (See Box p. 14). Although the regulation is not yet final, businesses that comply with the measure will be viewed by the government as making a good-faith effort to avert discrimination in wellness programs.

Complete Company Health Promotion Programs are still relatively new to corporate America and the legal implications of implementation and enforcement are not totally known. By their very nature, these programs potentially expose employers to discrimination lawsuits, disengaged employees and harmful public relations. Nonetheless, employers that make a good-faith effort to comply with current Health Care-related laws, discover ways to involve employees, and communicate strategically, will be able to minimize these risks while finding plenty of room to develop a creative and effective Company Health Promotion Program.

For many organizations, a smoking ban would not even apply to all employees. That is because currently 30 states and the District of Columbia prevent organizations from banning off-duty smoking.21 In Addition, 13 states prevent organizations from banning alcohol use away from work. Only six states have broad statutes that prevent organizations from prohibiting any lawful behavior. Michigan is the only state that expressly prohibits discrimination on the basis of weight, however the cities of San Francisco and Santa Cruz, Calif., also have this provision (San Francisco makes exceptions for police offi cers, fi refi ghters and the San Francisco 49ers football team). When beginning Employee Health Promotion Programs, organizations must keep in mind local statutes as well as established common law.

Savings of Voluntary Worksite Health Promotion Program = (number of participants x savings per participant) – (cost of program)
Savings of Incentive-based Workplace Health Promotion Program = (number of participants x savings per participant) – (expense of program + expense of incentives and rewards)
Savings of Mandatory Worksite Wellness Program = (number of participants x savings per participant) – (expense of program + expense of policy-related turnover + expense of limited talent pool)

Constructing Workplace Health Promotion Program policies in a employer that employs unionized staff members can pose unique challenges. Workplace Health Promotion Programs may be perceived by some unions as a condition of employment and therefore would be subject to collective bargaining between the parties. Still this postion can represent an opportunity for both groups, as a policy agreed upon between union leadership and management is likely to be received more favorably by staff members. The United Auto Workers and General Motors worked together to create and position a joint Workplace Health Promotion Program which has successfully reached more than 800,000 participants. (See Case Studies, UAWGeneral Motors LifeSteps Workplace Health Promotion Program, p.21).