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KEEP YOUR BENEFIT PLAN SPDS UP-TO-DATE

By Employment Resources

Employee benefit plans undergo changes constantly. Claims procedures are revised, benefits provisions modified, and new administrators or trustees named or their addresses or telephone numbers changed. Whenever such changes occur, plan sponsors have the obligation to communicate these to participants through a revised Summary Plan Description (SPD) or through a Summary of Material Modifications (SMM).

All ERISA-governed plans must communicate their terms to participants in the form of an SPD. Department of Labor regulations specify SPD format and content. Content requirements include, for example, contact information for the plan administrator; eligibility requirements for participation and benefits; a description of how benefits may be forfeited, suspended, etc.; how the plan is funded and the source of contributions; and procedures for claims and appeals. This is just a partial listing of content requirements, and these requirements vary to some degree depending on whether the plan is a pension or a welfare benefits plan.

As to format, the SPD must be written in a manner that the average plan participant can understand. Many plans fall short of meeting this requirement. According to an analysis from the Employee Benefit Research Institute (EBRI), important information contained in SPDs frequently is written at a level that is too high for the average plan participant. In the SPDs examined in the EBRI study (both single employer and multiemployer plans), information on eligibility, benefits and participation rights and responsibilities were written, on average, at a first-year-of-college reading level. Although an employer should take its workforce into account in drafting an SPD, with adults in the United States reading on average at an 8th or 9th grade level, an SPD written at a first-year-of-college reading level would be appropriate for very few employee groups.

As noted at the beginning of this article, when changes are made to an employee benefit plan, the SPD must be revised to reflect this. If the change has been material, an updated SPD, or an SMM, must be issued not later than 210 days after the end of the plan year in which the material change was made. (A shorter time frame of within 60 days of the change applies if the plan is a group health plan and the change is a reduction in covered services or benefits.) In any case, an updated SPD must be issued at least every five years if the plan has undergone material changes, and at least every 10 years if it has not.

Given the specificity of the SPD requirements, prudence dictates that employers review their SPDs periodically to ensure they remain current, and reflect plan provisions accurately. Also, changes in law or the issuance of regulations might require an SPD review and revision.

When a benefit plan is insured, the carrier will supply a certificate of insurance or other booklets or documents that describe the benefits. However, do not assume that these documents fulfill the SPD requirements. These could be generic documents that do not reflect specific provisions that apply to your company’s plan; they also were probably written with state insurance laws in mind, not ERISA. The SPD requirement is a plan sponsor obligation, so that is where the penalties will attach in the event that an SPD is found to be lacking.

RECENT STUDY CONFIRMS EMPLOYEES’ HEALTH RISKS CAN DECREASE PRODUCTIVITY, INCREASE COSTS

By Employment Resources

Although logic tells us that healthier workers are likely to be more productive than those with health risks, a recent study confirms this, finding that individuals with a number of health risks have seven times more lost productivity than those with no identified health risks. Health risks most strongly associated with on-the-job productivity loss were back pain, mental well-being (depression) and stress. Also, the chances of productivity loss rose as the number of health risks increased.

The study, published in the Journal of Occupational and Environmental Medicine and conducted by StayWell Health Management researchers and John Riedel, a health and productivity expert, included data from 106 companies in five industry sectors, representing responses from nearly a quarter of a million individual employees. Questions on health and work performance were incorporated into the companies’ health risk assessments to collect the data. Employees considered to be at low risk were classified as a NIF (Normal Impairment Factor) group. According to the study, “NIF captures the amount of productivity loss experienced by individuals who are at low risk … thus representing the level of productivity loss that health improvement initiatives targeting these risks will not affect.” Thus, the NIF essentially serves as a benchmark to gauge the amount of productivity loss that could be eliminated through various health risk reduction strategies.

The study included eight health risk areas: Alcohol use, back pain, driving, physical activity, stress, tobacco use, weight and mental well-being (depression). Productivity loss was associated consistently with “at risk” health status for all of these factors, with the greatest productivity loss observed for those at risk for back pain, stress and mental well-being. Individuals at elevated risk for back pain reported 13% more productivity loss than those at low risk; those at risk for depression reported 7.4% greater productivity loss; and those at risk for stress reported 4.8% greater productivity loss. When measured as lost time, ongoing back pain was responsible for 5.7 weeks of lost productivity each year, depression for 2.4 weeks, and stress for 1.1 weeks. Thus, according to the study, these three areas present the greatest potential for productivity improvement through intervention, such as targeted wellness initiatives.

Greater productivity loss also was observed among individuals who had multiple health risks. Individuals in the study had an average of 2.4 health risks each, and each additional risk increased productivity loss by 2.4%. An individual with all eight risk factors experienced a productivity loss of 24%.

How do these estimates of productivity loss impact an employer’s bottom line? The researchers calculated that an employee with low health risks experiences an average of $1,472 per year in lost productivity, while a “more typical” employee with three health risks averages $5,952. The study estimates that if 100 people with three health risks were to eliminate just one health risk, this could mean productivity gains worth $149,400 for an employer.

For employers, a study such as this one provides ample financial justification for investments in wellness initiatives. Be sure to contact our office today for more information. Looking at the dollar cost of productivity losses brought about by employees’ health risks, it’s easy to see that targeted interventions aimed at reducing employees’ health risks for identified conditions or behaviors can readily result in a return that exceeds the investment made in such initiatives.

IN TOUGH ECONOMY, CONSUMERS CUT BACK ON HEALTHCARE

By Employment Resources

In addition to anxiety and stress, the toll today’s troubling economy is taking on individual health can be seen in the cutbacks people are making in obtaining health care and prescription drugs. Many people are foregoing medical visits and services, choosing not to fill prescriptions, and dosing filled prescriptions in ways to make them last longer.

Several recent surveys document this worrisome trend:

  • A survey of consumers by the National Association of Insurance Commissioners found that 22% have reduced the number of times they see a doctor as a result of the economy, and 11% have cut back on the number of prescription drugs they take or have adjusted the dosage of their medications to make a prescription last longer.
  • The Kaiser Family Foundation’s first tracking poll for 2009 found that more than half (53%) of Americans say their household has cut back on health care in the past 12 months, due to cost concerns. Steps taken include relying on home remedies and over-the-counter drugs rather than visiting a doctor (35%), delaying seeking needed health care services (27%), skipping a recommended medical test or treatment (23%), not filling a prescription (21%), and cutting pills in half or skipping doses to make a prescription last longer (15%).
  • A survey from Consumer Reports found that nearly 70% of respondents had taken steps to “afford” their prescription drugs over the past year, and 28% did so in a way that had potentially harmful health effects. These measures included failing to fill a prescription (16%), skipping a dose (16%), taking an expired medication (11%), cutting pills in half (10%), and sharing a prescription (4%). Individuals under the age of 65 without prescription drug coverage were most likely to engage in such risky behavior in an attempt to control their costs.

That consumers have cut back on prescription drug spending is reflected in data from IMS Health, which reports that prescription drug sales in the United States grew only 1.3% in 2008. This is down from the 3.8% sales growth seen in 2007, a figure that was considered low at the time — the lowest growth rate since 1961 — and down from a rate of 8% in 2006.

Although everyone is concerned about getting health care and prescription drug spending under control, no one wants to do that in ways that endanger individual health or lead to the worsening of a chronic condition, requiring added intervention and spending down the road. When it comes to prescription drugs, consumers can stretch their health care dollars by using generics. However, according to Consumer Reports, nearly half of consumers harbor reservations about generics: 27% say generics have different side effects than their name brand counterparts, 22% believe they aren’t as effective, 18% believe they don’t meet the same federal standards, and 16% say they just aren’t safe. These misconceptions must be recognized, battled and corrected if generics are to achieve their potential in aiding prescription drug cost control in a safe and appropriate way.

CONSUMER-DIRECTED HEALTH PLANS: WHAT’S FACT AND WHAT’S FICTION

By Employment Resources

Though participation in consumer-directed health plans is growing, only a small percentage of employees join these plans, and even fewer set up health savings accounts (HSAs). According to a survey from the Employee Benefit Research Institute, in 2008, 3% of the insured population, or 4.2 million individuals, were enrolled in a consumer-directed health plan, defined as an HSA paired with a high deductible health plan (HDHP). More — 11%, or 13.4 million individuals — were enrolled in an HDHP, and of these, 42% were eligible to contribute to an HSA, but chose not to do so.

Misunderstanding the mechanics of HSAs and ignorance of their potential advantages keep many people who are eligible for an HSA from seriously considering opening an account. Similarly, employees who have a consumer-directed health plan option might see the high deductible feature as offsetting, and not consider other advantages of the plan. If your company offers employees the opportunity to participate in a consumer-directed health plan, or if you are considering making this opportunity available, it’s important that employees understand how these plans work, so those for whom they are appropriate can benefit from this form of health care coverage.

Here’s a quick rundown of a few common consumer-directed health plan and HSA fictions, along with the clarifying facts.

  • Fiction: The only reason an employer implements a consumer-directed health plan is to shift health care costs to employees. Fact: An employer makes an investment in a consumer-directed plan, just as it does with a traditional plan. Though the premium cost might be less for the employer, it is less for the employees’ share, too, and many employees would rather pay less for health care upfront (the premium) and the bulk of their costs at the time of service. Consumer-directed plans really represent an expansion of health plan choices for employees.
  • Fiction: Since they’re paired with a HDHP, HSAs only make sense for individuals who are young and healthy. Fact: An HDHP-HSA pairing provides comprehensive health care coverage at an affordable price for individuals with all sorts of medical needs. Though the HDHP deductible is higher than that found in more traditional plans, the premium is lower as a result. So, even if the account holder must dip into the HSA to pay for expenses that would be covered at an earlier point by a more traditional plan, this must be balanced against the premium savings. Also, as noted below, most preventive care is not subject to the deductible and can be covered at 100% by the HDHP.
  • Fiction: Because of the HDHP high deductible, HSA funds are quickly depleted; even for individuals with only basic health care expenses, an HSA account holder is unlikely to have any funds left to roll over at the end of the year. Fact: For many individuals, the bulk of their medical expenses consists of preventive care, and HDHPs can cover preventive health care expenses at 100% before the deductible. Depending on plan design, such expenses can include well-baby and well-child doctors’ visits and immunizations; adult physical exams and immunizations; and routine adult screenings, such as mammograms, Pap smears, prostate screenings and colonoscopies.
  • Fiction: Unless you can predict your annual health care expenses accurately, you stand a chance of losing the money you contribute to an HSA. Fact: HSA funds that are unused in one year — whether they represent the contributions of the account holder or employer — carry over, and can be used to pay for health care expenses incurred in future years, even in retirement.

Resolving the confusion surrounding these and other consumer-directed health plan misconceptions can help employees better understand and appreciate the potential benefits of participating in these plans.

WHAT DRIVES THE COST OF A PRESCRIPTION DRUG?

By Employment Resources

Prescription drug costs continue to be one of the fastest growing components of total health care costs. According to a 2008 report from the Kaiser Family Foundation, spending in the United States for prescription drugs in 2006 was $216.7 billion, more than five times what it was in 1990. Though spending for prescription drugs was one-third of that for hospitals and half of that for doctors’ services, the annual rate of increase for spending on prescription drugs has exceeded that for these other services in all but one of the last 11 years.

Nearly half (44%) of spending for prescription drugs is paid for by private insurance. Since employers are the principal source of health insurance coverage in the United States, they fund a major portion of the spending for prescription drugs. Therefore, it’s worthwhile for employers to understand the factors that go into the ultimate cost of the prescription drugs that are paid for, in part, by employee benefit plans.

When a new drug is first brought to market, the company that developed it enjoys some patent protection for the drug, which gives that company the exclusive right to sell that drug in the market for a certain period of time. This protection is intended to help pharmaceutical companies recover some of the cost of drug research and development, which can be substantial. By providing patent protection for a period of time, companies are encouraged to take the financial risk associated with new drug development. Only after the patent protection has expired can competitors bring lower-cost generic versions of the same drug to market.

When a company develops a new drug, it decides what price to charge for it, taking into account factors such as the research and development costs associated with the drug; whether other, different drugs with similar therapeutic effects are available; market demand; the current economic and competitive climate; and advertising costs and marketing strategy. While in some other countries governments play an active role in setting the prices for prescription drugs, this is not the case in the United States.

The price a drug manufacturer sets for its product is just the first piece of the equation that determines what the drug ultimately costs at the time it is dispensed to the consumer. Health plans and pharmacy benefits managers (PBMs) will negotiate with pharmaceutical manufacturers for discounts and rebates on their prescription drug products. The success of such negotiations and size of incentives achieved can vary significantly depending on a number of factors, including the utilization volume of the plan/PBM for the manufacturer’s products, placement of the manufacturer’s products on a plan formulary or preferred drug list, etc. Health plans and PBMs also can save costs by trying to achieve savings at the pharmacy level of the prescription drug distribution chain. This can be done by establishing networks of preferred pharmacies that agree to accept an established reimbursement rate in exchange for being included in the network, and by setting up or working with mail-order pharmacies.

Though these factors that establish the price of a prescription drug are out of an employer’s hands, there are things that any company with a prescription drug benefit can do to have some impact on what prescription drugs will ultimately cost the plan. Effective plan designs that encourage the use of generics and other preferred medications and that succeed in getting employees to use preferred and mail-order pharmacies can dramatically lower plan spending on prescription drugs. Working with a PBM or health plan that is proven effective with these strategies can be key in getting the most for your prescription drug dollar.

WELLNESS PROGRAMS PAY OFF IN THE LONG RUN

By Employment Resources

Various studies of the return on investment (ROI) generated by wellness and health promotion programs establish that these programs can indeed provide payback on the dollars invested in them. Regardless of the ultimate payback, however, an employer wishing to establish such programs still will need to find the financial resources to set them up — an investment that might be small or large, depending on the extent of the program. Given the added costs generated by employees with unhealthy lifestyles or modifiable health risks, it’s worth exploring all possible ways to fund a wellness initiative.

Employees’ unhealthy behaviors add greatly to a company’s health care costs. Using tobacco, living a sedentary lifestyle, being overweight or obese, eating a diet lacking in nutrition, or failing to properly care for a controllable chronic health condition all can take a toll on a company’s bottom line, as well as on an individual’s health. According to data cited in a report from the Wisconsin Public Health & Health Policy Institute, illness and injury associated with an unhealthy lifestyle or modifiable risk factor can account for at least 25% of employee health care expenditures.

This same report cites a handful of studies that support the proposition that wellness, health promotion and disease prevention programs provide “multifaceted payback on investment,” through improved worker health, reduced benefit expense and enhanced productivity. Studies cited reported ROI ranging from approximately $1.50 to close to $6.00 per dollar invested, varying by type of program and by whether health care costs alone, or also factors such as reduced absenteeism and improved productivity, were considered. Another study published in the Journal of Occupational and Environmental Medicine found that employers could save $1.65 in health care costs for every dollar spent on a comprehensive employee wellness program.

If you accept that wellness programs will save you money over time, you still need to find the money to get such a program up and running. Try not to let funding concerns convince you to skimp on the quality of the program, as it takes a well-designed, targeted and comprehensive program to achieve the kind of ROI found in the studies. That said, consider these funding possibilities:

  • Implement the wellness program at the same time that you make other health plan changes. If your benefit program does not include any high deductible health plan options (with lower premiums), now would be a good time to think about adding a consumer-driven plan to the mix.
  • Make a health risk assessment part of the wellness program, charge a higher health plan premium rate for employees who decline to take the assessment, and apply these funds to wellness program costs.
  • Ask your health plan vendors what wellness programs they offer and whether they are integrated with your current plan, or if they could be added to your plan at a discount.
  • Survey employees to ascertain what types of programs they would use and, furthermore, would be willing to contribute to.
  • Look at your benefits program overall for possible sources of funding. For example, are there little-used benefits that could be converted to a voluntary program? Or any high cost (for both employer and employees) health plan options that draw a low enrollment and, potentially, could be eliminated?

Employees with unhealthy lifestyles or modifiable health risks are likely to cost more to employ. It’s worth taking the time and exploring all options to fund programs that target these employees’ needs.

NEW LEGISLATION AWARDS COBRA SUBSIDY TO INVOLUNTARILY TERMINATED EMPLOYEES

By Employment Resources

The U.S. Department of Labor has issued four model COBRA notices which cover the provisions of the American Recovery and Reinvestment Act of 2009. These model notices will enable employers to notify former employees and their dependents how to take advantage of COBRA coverage and the subsidy.

There are four new notices available for different types of plans and individuals:

  1. General Notice (Full version) – Send this notice to ALL qualified beneficiaries going forward. This combines a general COBRA notice with the premium reduction provisions of ARRA.
  2. Abbreviated Version of the General Notice – This notice covers just the premium reduction information under ARRA – Send this notice to individuals who experienced a qualifying event during on or after September 1, 2008, have already elected COBRA coverage, and still have it.
  3. Alternative Notice – This notice is sent to persons who became eligible for continuation coverage under a State law. Plans will need to modify notice to bring it into compliance with their applicable state law.
  4. Notice in Connection with Extended Election Periods – This notice includes information on ARRA’s special election opportunity along with the premium reduction information. This notice MUST be provided to these individuals by April 18, 2009. Plans subject to the Federal COBRA provisions MUST send this notice any “assistance eligible individual” who:

    a. Had a qualifying event at any time from September 1, 2008 through February 16, 2009; and,
    b. Either did not elect COBRA continuation coverage, or who elected it but subsequently discontinued COBRA.

Additional References

http://www.dol.gov/ebsa/COBRAmodelnotice.html
http://www.dol.gov/ebsa/faqs/faq-cobra-premiumreductionEE.html

EMPLOYERS MUST GET UP TO SPEED ON CHIP REAUTHORIZATION ACT

By Employment Resources

New special enrollment rights, together with notice and disclosure requirements for employers, are among the provisions in the Children’s Health Insurance Program (CHIP) Reauthorization Act of 2009, signed into law by President Obama on February 4, 2009. CHIP is the federal program that gives matching funds to states in order to provide Health insurance to low income families with children. The Reauthorization Act expands the program, but is also including new special enrollment rights and notice and disclosure requirements for employers.

The law creates special enrollment rights for employees and their dependents who are “eligible but not enrolled for coverage” under an employer’s group health plan in two situations: The employee’s or dependent’s Medicaid or CHIP coverage is terminated as a result of loss of eligibility, or the employee or dependent becomes eligible for a subsidy (see next paragraph) under Medicaid or CHIP. An employee exercising one of these special enrollment rights must do so within 60 days of Medicaid/CHIP termination or becoming subsidy-eligible. (Note that this special enrollment rights period is twice as long as that under the HIPAA special enrollment rights situations.) These special enrollment rights became effective April 1, 2009.

States can provide health care coverage directly to CHIP-eligible individuals, but the law also allows them the option of paying a premium assistance subsidy so that low-income employees can cover CHIP-eligible children under an employer group plan. The subsidy can be provided to the employee as a reimbursement for premiums paid to the group plan, or to the employer sponsoring the plan. Employers can opt out of receiving the subsidy payment, in which case it will be paid to the employee. The subsidy can only be offered for what the law refers to as “qualified employer-sponsored coverage” — a plan for which the employer contributes at least 40% of the cost, and not including health care flexible spending accounts and high deductible health plans.

In states that provide a premium assistance subsidy, employers will be required to give employees notice of the potential opportunity for the subsidy. Such a notice will need to be provided when notifying the employee of plan eligibility, when open enrollment materials are distributed, or when providing the summary plan description (SPD). The Department of Health and Human Services (HHS) is to develop a model notice by February 4, 2010; this notice requirement will become effective for employers beginning with the plan year after issuance of the HHS model notice.

The law also creates a disclosure requirement for group health plans. The purpose of disclosure will be to help states determine eligibility for the subsidy and its cost-effectiveness. HHS and the Department of Labor (DOL) will form a working group to develop a model disclosure form, and employers will be required to disclose information upon request beginning with the plan year following issuance of the model disclosure form.

The law provides for penalties of up to $100 a day for failure to comply with either the notice or disclosure requirements.

So what should employers be doing now to get up to speed on this new law?

  • Identify all states where employees reside and determine whether the state provides a premium assistance subsidy.
  • Review health plan documents and amend them as necessary to provide for the new special enrollment rights. As noted above, employees are able to exercise these special enrollment rights effective April 1, 2009.
  • Review any health insurance contracts’ coordination of benefits (COB) provisions, because states will be the secondary payer for services provided under employer group health plans for which a premium assistance subsidy is provided.
  • Stay alert to developments from the DOL and HHS concerning this law, and be prepared to take compliance steps as soon as the model notice and disclosure forms are released.

PREVENT FMLA FRAUD BY REQUIRING CERTIFICATION

By Employment Resources

The Family and Medical Leave Act (FMLA) requires covered employers to grant eligible employees up to 12 weeks of unpaid leave during a 12-month period for specified family- and medical-related reasons. Although administration of FMLA leave associated with the need to care for a newborn or newly adopted child can be quite straightforward, handling leave requests based on an employee’s own serious medical condition, or the need to care for an immediate family member with a serious medical condition, can be more complicated, when questions about the authenticity of the medical reason present themselves.

In any company, most employees will respect the rules and only request FMLA leave when they need and are legally entitled to it. But as any employer knows, there always seem to be a few employees who try to bend the rules and play the system. What can employers legally do to minimize abuse of FMLA leave requested for medical reasons?

A first step in dissuading attempts at fraudulent FMLA medical-based leave is to require that employees document the need for leave with medical certification. An employer may require that, for any leave taken due to a serious health condition, the employee provide a medical certification confirming that a serious health condition exists. Certification may be requested whether the stated reason for the leave request is the medical condition of the employee or of an immediate family member. The employee must be allowed at least 15 calendar days to submit the certification.

When the employee supplies the certification, examine it to determine whether it does in fact document a serious medical condition, and whether it is complete and authentic. If the certification is incomplete, require that the employee correct it. If you have any suspicions about the authenticity of the stated reason—for example, if you suspect that the health care provider may be exaggerating the seriousness of the medical condition at the request of the employee—the law allows you to require the employee to submit a second certification. This is at company expense, and you can choose the provider for the second opinion. If the opinions conflict, the employer can require a third — and final — certification.

Of course, certifications that do support the employee’s or immediate family member’s serious medical condition should result in leave approval, just as those that do not document this should result in the leave request being denied.

An area that can cause particular frustration for employers involves requests for intermittent leave. FMLA permits employees to take leave on an intermittent basis or to work a reduced schedule when medically necessary to care for a seriously ill family member, or because of the employee’s serious health condition. To get a handle on whether any employee might be abusing this FMLA leave provision, look for patterns in employees’ FMLA leave requests. Does the employee’s medical condition always seem to flare up on Mondays, Fridays, or days preceding and following holidays? Do intermittent leave requests always coincide with school holidays, or certain weeks in the summer? Employees who require or desire time off work during such times should not be looking to FMLA to provide it. Employees who do legitimately need intermittent leave for foreseeable medical reasons should work with their employer to schedule leave so as to not unduly disrupt the employer’s operations.

Although implementing strategies to combat FMLA fraud, it’s also important that your business doesn’t suffer when employees are out on FMLA leave, whether legitimately or not. If your business has a pattern of FMLA-based absences at noticeable times, schedule workers accordingly.

Correct administration of FMLA leave is an important compliance issue for employers. Lengthy final regulations were issued by the Department of Labor in late 2008, and were effective January 16, 2009. These regulations include provisions on establishing a “serious health condition” and clarifying administration of intermittent and reduced schedule leave, and on what employers can do regarding inadequate medical certifications.

HELP EMPLOYEES TO SEE THE BENEFITS OF HEALTH RISK APPRAISALS

By Employment Resources

As health care costs have risen, employers have searched for ways to bring these costs under control. When cost shifting and plan redesigns did not bring about desired results, attention turned to ways to engage employees more actively in managing their health. Health risk appraisals (HRAs) are considered by many to be the first step in engaging employees in their health management.

An HRA is a tool for gathering information on various aspects of one’s health and gauging appropriate interventions and follow-up care. An HRA usually consists of a questionnaire, frequently completed online through the health insurer’s or wellness program provider’s Web site, that gathers information on various health aspects: weight/body mass index, nutrition, exercise habits, lifestyle, personal and family medical history, etc. The HRA might be in conjunction with screenings for blood pressure, cholesterol and blood sugar levels. The HRA provides feedback to the employee on health status and suggestions on how to improve. These might include directing the employee into a disease management program, to a nutritionist, or for follow-up care with the employee’s regular physician.

On paper, an HRA seems like a logical way to begin to become more involved in one’s personal health management. Yet, many employees decline to participate when an HRA is available. This reluctance might result from concerns about the employer’s motives in offering the HRA. Employees might wonder whether their answers to the questionnaire and any data gathered about their health will be kept confidential. They might be concerned that if health information is shared with their employer or insurer, they will suffer negative consequences, such as higher insurance rates or even a loss of coverage.

Though these fears are unfounded, employers need to address them head on in order to convince employees of the privacy of the information contained in the HRA. Be sure employees are aware of their HIPAA privacy rights, that personal health information is protected from disclosure, and that the information gleaned from the HRA is for their use and benefit, not for that of the employer or insurer.

Beyond addressing employee concerns about privacy, probably among the most effective communications involving HRAs answer the employee question, “What’s in it for me?” Make sure that your HRA communications include these messages:

  • Completing an HRA will give you important information about your health, and knowledge is one of the best tools you can have in staying healthy.
  • What you learn from an HRA can alert you to any health issues that you might be prone to or that are in their early stages. This information can lead you to appropriate screenings, preventive care and disease management programs.
  • If you stay healthier your health care costs will probably be lower over time. By dealing with a health issue at an early stage your treatment options are likely to be wider and less expensive.

Many employers take the additional step of offering incentives for participation in health risk appraisals. In a survey from Watson Wyatt Worldwide and the National Business Group on Health, more than half of the firms responding (53%) offered employees financial incentives for completing an HRA. Premium or deductible credits were more effective than cash at boosting HRA participation—73% of companies that offered premium credits and 67% that offered deductible credits had at least half of their workforce participate in an HRA, compared with 17% that offered cash and 12% that offered no incentive.

An HRA is an important first step toward engaging employees in their health management and can be the entry point for other wellness programs. By encouraging employees to participate in an HRA, you’ll be helping them to maintain better health and likely saving them, and your company, health care costs down the road.