Health Tips A to Z

A Worksite Health Promotion Program without objectives is somewhat akin to taking a family trip without any planning; you won’t know where you’re going, how to get there, what you want to do once you have arrived, or even whether or not you have arrived!  The trip may end up ok, or it may end up disastrously.  Yet, with a modest amount of thoughtful planning, you broaden your chances for a successful experience.  Clear objectives are needed to plan your wellness program in order to ensure success!

Wellness program goals and objectives are different from one company to another depending on the population, needs, interests and resources.  Nevertheless, well thought out objectives based on your company’s needs assessment will form the foundation of a successful wellness program!

Corporate Health Promotion Program Mission Statement

The first consideration is a mission statement for your Worksite Wellness Program. The mission statement is the overall expression of what the Worksite Wellness Program Committee wants to accomplish by implementing a wellness program.  It is valuable to consider how your Worksite Wellness Program fits in with the business mission statement, contributes to the overall mission and supports the business bottom line.  This will integrate your efforts throughout the business operations.  

Here are some examples of Corporate Health Promotion Program mission statements:

“At XYZ Company, maintaining an environment that supports employee health and safety is our underlying value.  It is the mission of the Corporate Wellness Program to assist  in creating Corporate Wellness Program services that fosters and upholds that value.”

“It is the mission of the XYZ Company Health Promotion Program Committee to cultivate healthier lifestyle choices to lower health risk factors, improve overriding well-being, and maintain a advantageous, active work force.”

Company Wellness Program Goals

The goals further define your mission and are based on your needs assessment.  Depending on the needs assessment, management expectations and employee interests, examples of goals can include:

The objective(s) of XYZ Company Health Promotion Program in year XXXX is to:  (one or more of the following examples)

• Reduce absenteeism by one day per employee
• Cut down on musculoskeletal injuries by ten%
• Cut down on unnecessary emergency room visits
• Lower or contain health care costs
• Improve dietary habits of employees
• Cut down on health risk factors  

Corporate Health Promotion Program Objectives

Specific Employee Health Promotion Program objectives help meet your long-term objectives and goals.  Both short term and long term objectives ought to be developed as the stepping stones to accomplish the objectives and goals.  In addition to objectives for the expected participant outcomes, process objectives ought to also be developed for the program process itself.  For example, process objectives may include how many workers you want to take part in the programs, how many sessions on a topic will be provided, the type of wellness sessions that will be implemented, etc.

Objectives must be easily measurable within a set time frame.  Try using the SMART formula to set up both your long and short-term goals and objectives:

• Specific (one behavior or outcome)
• Measurable (one result that can be inspected or evaluated),
• Attainable (but also challenging),
• Realistic (do you have the resources to achieve?), and
• Time specific (within 3 months – up to 5 years)  

This is the who, what, when, where, why, and by how much method.  By way of example, a goal for a weight loss program that has an overall intention of improving healthy eating and promoting a healthy weight is that:

Participants (who) will lose an average of .5 – 1 lbs per week (specific what that is measurable) at the end of the 12 week lunchtime program (time specific what, when and where) for a minimum of 6 lbs weight loss per attendant (attainable and realistic).

Or:

Members (who) will attend 11 of the 12 sessions (specific what that is measurable) and name at least one healthier eating change at the end of the program (specific what, when, where)

An example of an intention for coaching staff members with elevated cholesterol might be:

To lower the total cholesterol (specific what) of high risk staff members with cholesterol over 240 mg/dl (specific who) to 200 mg/dl (measurable how much) through one-on-one counseling sessions provided at the worksite (where) by X date (ex, after 6 months) (attainable, realistic & time specific when) to lower the risk factor for heart disease (why).  

And one last example of a process objective for a tobacco cessation program with an overall objective to help  participants in committing to quit for life:

By the end of the 4-week tobacco cessation program, ten percent of the participants will have quit smoking.  Each participant will be contacted at 3 months, 6 months and 12 months from the program’s end to determine quit status (process mission) and ten percent of those who quit will still be smoke-free after one year.

You have now completed Steps 1 through 4, including implementing your Company Wellness Program Committee.  It is now time to plan your wellness activities!

Before you start organizing your Corporate Wellness Program you need to know where you are now and then decide where you want to go.  Completing a thorough needs assessment is vital to the performance of your wellness program for two reasons:  First it ensures that your Corporate 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 supplies the information you will need to evaluate the effectiveness of your wellness program.

It is often tempting to rush the assessment – especially when time is short or those with experience already have an idea of needs.  Do not give in to this temptation!  It is vital that you understand what your business needs are, what management expects, and what workers want as well as expect, before you create a Corporate Health Promotion 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
• Rates of Absenteeism
• Business Culture Audits
• Employee perceived needs and health risks
• Senior Leadership’s expectations or desired outcomes

There are many ways to assess this information.  Although some of data gathering process may be time consuming, remember that it is nonetheless critical to plan programs that target specific problems.  This information will be vital to set 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 Company Group Summary Report
• Health Screenings such as cholesterol, Blood Pressure and blood sugar 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 Worksite Wellness Program Committee can review the results and start planning and prioritizing program options.  Starting should be based upon goals/objectives and identified outcomes, Step 4 of the seven step process!

Securing an active Company Wellness Program Committee supplies opportunities for both senior staff and employee participation in the program.  The Committee ought to be a team of workers and managers who formally meet to plan activities to reward healthier employee lifestyles.

Typical Functions of a Company Wellness Program Committee:

• Analyzing needs & interests
• Coming up with program ideas
• Beginning activities
• Establishing communication plans
• Promoting programs to co-employees
• Serving as champions of the Corporate Wellness Programs
• Assisting with evaluation  

Your Corporate Health Promotion Program Committee ought to be representative of all echelons of the corporation.  Consider all areas of the workforce – multiple sites, shift staff members, diversity (race, gender, ethnicity), and departments.   It’s also significant to consider who will chair or co-chair the Corporate Health Promotion Program Committee and whether or not there are the finances to support a Corporate Health Promotion 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 organization size and resources, if you already have a organization Safety Committee you might want to consider making it the Safety & Employee Wellness Program Committee.  You are able to request volunteers or invite workers to take part.  

The number of Company Health Promotion Program Committee participants depends on the size of your business; however, you need a sufficient number of 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 important to include skeptics of wellness as well and not just those employees already living healthy lifestyles.  

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

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

Establish an effective Employee Health Promotion Program Committee!  The Employee Health Promotion Program Committee ought to meet on a regular basis with a planned agenda and action items.  Successful Wellness Committees have a shared mission, vision and objectives and goals.  Members must believe that their participation is worthwhile and appreciated, that their work is significant, 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 businesses have implemented.

As with any program, the two key elements for the effectiveness of your wellness program are senior staff support & employee participation.  Upper Management sets the vision and provides the resources from which action plans flow.  Genuine support from senior personnel also lends credibility to the wellness plan.  It is key that senior staff be visible supporters and role models for your Worksite 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 ought to have a chance to offer input and feedback through needs & interest surveys and program assessment tools.  The information gathered ought to 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
• Talking About Wellness Interests During Department gatherings
• Distributing and Encapsulating a Needs & Interest Survey
• (Including|Allowing for|Making sure to include} a Chance to Give Recommendations on Each Assessment Tool  

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

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

A key to a efficacious Worksite Wellness Program requires management commitment and employee involvement.

Worksite Wellness Program Step 2: Create a Worksite Wellness Program Committee

An active Worksite Wellness Program Committee sees to employee involvement, supports buy-in, management support, and maintains a team that is ready to take action to integrate wellness programs.

Corporate Wellness Program Step 3: Gather Data to Identify Key Needs and Expectations

The next vital step is to base the Workplace Wellness Program on the needs and interests of your business and its staff members.

Worksite Health Promotion Program Step 4: Create Goals and Objectives

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

Workplace Health Promotion Program Step 5: Organize a Detailed Action Plan

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

Workplace Health Promotion Program Step 6: Select and Launch a Plan

Armed with the needs assessment results, a Company Wellness Program Committee, objectives and goals it’s now time to put your plan into action!

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

Evaluation is a critical step to keep a program on target, as well as to guarantee that the program is reaching its goals and objectives or achieving the desired outcome.

In Summary

These Seven Steps outline considerations for a all-inclusive approach to establishing an effective wellness program.  Are you able to start components of wellness activities without referring to these steps?  Yes, of course, but you may not have the sustainability or ability to bring about desired outcomes.  Following the Seven Steps does not have to be confusing or burdensome.  A very simple approach can achieve a efficacious wellness program!

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

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

The program design options hinge upon the objectives and desired outcomes of your program.  If your objective is to help staff members modify behavior, cut risk factors, or save medical care dollars then your wellness program would be designed to accomplish those outcomes and a budget would be significant to support that design.  

Wellness program design options vary, depending on desired outcomes and budgets.  Each level has pros and cons.  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, planning activities such as an employee health & wellness fair or lunchtime education sessions, or having brochures available do not usually result in behavior modification, but may increase awareness on a topic.  If the intention is behavior modification then a different design is necessary, such as Lifestyle/Behavior Change Programs and Corporation Support.  The outline below outlines the wellness design levels with a short explanation.

Awareness Programs:  At this level a organization makes health information available and accessible to employees.  This type of program frequently includes brochures on a variety of subject matters, wellness articles in newsletters, bulletin board displays, e-mail health messages, etc.   Also, most health fairs are designed as awareness programs with vendors offering information and offering wellness screenings to employees.  

Awareness programs are inexpensive and do not require extensive employee or organization time commitments.  Nonetheless, these programs do not usually result in behavior change.  Improving awareness isn’t usually enough to generate lifestyle changes for most American citizens, unless used to excite staff members to register for a program being offered at the organization or community on the topic.  An example of this would be providing information on the harmful effects of smoking and inviting staff members who smoke to register for a tobacco cessation class.

Education Programs:  Educational programs frequently provide more information on a topic and can also provide time for Q & A, but are similar to awareness programs.  An example is lunch-n-learn sessions on a health related topic.  These cost the company a bit more than awareness programs; however, they remain inexpensive and do not require a whole lot of time for planning or attending a session.  Again, increasing awareness and offering information may not lead to the desired behavior change unless ongoing backing or incentives and rewards are also planned.

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

Examples are tobacco cessation classes, weight loss and weight management meetings, or an ongoing physical activity program.

Environmental and Employer Support:  Environmental reinforcement is frequently considered the highest and most valuable level to include when beginning 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 workplace fitness centers,
• Ensuring healthy snack machines choices,
• Offering healthy diet choices in the cafeteria, and/or
• Creating flex-time policies.  

Other examples include subsidizing healthy vending machines or cafeteria choices; reimbursing health club or weight loss and weight management program memberships; or providing insurance incentives and 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 results will be.  For example, a corporation can have smoking 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 go to a community program; and/or on an environmental support level can establish a smoke-free workplace and grounds, offer decreased medical insurance for non-smokers, or offer pharmacological quit smoking aids for free.

Company Health Promotion Program: Components for Success

There are several important elements that need to be considered to see to the success of your Employee Wellness Program or Employee Wellness Program.  These include:  

• Upper Management Reinforcement & Employee Involvement
• Active Employee 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 benefits of healthy employees include:

• Reduced Health Care expenses
• Lowered Injuries
• Reduced Rates of Absenteeism
• Boosted Morale and Loyalty
• Increased Productivity
• Lowered Use of Healthcare Benefits
• Diminished Workers’ Comp/Disability
• Positive Perception in Community
• Reduced Turnover
• Improved recruitment for able staff members

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

Consider the health risk factors that are increasing chronic diseases for adults:

• 59 percent of American citizens are overweight or obese
• More than 60% of adults do not exercise regularly
• More than 75% of adults do not eat the minimum recommendations for fruits and vegetables
• Cardiovascular disease is the most common cause of death and the primary cause of death in smokers
• 26% of staff members reported they were often or very often burned out or stressed by their job  

Medical Care expenses are Growing:  Medical Care expenditures are at a record level of $1.7 trillion with no signs of holding steady, let alone decreasing.  The average cost of yearly medical spending is over $5,000 per person and including dependents almost $10,000.  Recent data shows that medical related expenses 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, physical inactivity, and poor nutrition.

Stress Levels are On the Rise:  As business resources diminish and employers adopt leaner work practices, the effects of absenteeism and productivity lost have an increased influence.  In a new national poll, 78% of American citizens described their jobs as stressful, and most felt that stress levels have risen over The last decade.  Additionally, high levels of business stress can negatively affect a business by rising injuries, absenteeism, and medical costs while decreasing productiveness.  Simple solutions such as stress management education, flexible work schedules, quality social interaction, and increased participation in business decision-making can better stress levels in the workplace.

What is the Initial Cost and Time Investment for a Workplace Health Promotion Program?

The expense depends on the type of Workplace Health Promotion Program implemented.  There are several options to promote employee health with pros and cons of each.  The program design depends on the goals of the wellness program, the organization resources, and the community resources available.  

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

When well-planned and based on your goals, any of these programs have the potential to help you succeed.  Refer below to Company Wellness Program Design Options for additional ideas.

A Employee Wellness Program is an organized program to help and support workers in establishing healthier lifestyles.  This can include rising employee awareness on health subject matters, scheduling behavior change programs, and/or establishing corporation policies that support health-related objectives.  Programs and policies that promote increased physical activity, tobacco use prevention and cessation, and healthy meal selections are a few examples.  

Dimensions of Wellness

Wellness is much more than fitness alone.  In addition to physical fitness, the dimensions of good health include:

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

These dimensions are frequently portrayed as a “life wheel” with examples of health dimensions that include fitness, diet, purpose in life, monetary planning, social wellness & support systems, stress management, mind-body health, career planning and constant learning.   The key for personal health is keeping the “life wheel” in balance.  A accross the board workplace wellness program addresses most, if not all, of these dimensions.

Why Corporate Health Promotion Programs?

staff members spend a great deal of time on the job, and the reality is that our traditional work-week is growing.  In fact, the typical American now labors about 47 hours a week.  Additionally, items such as modems, laptop computers, cellular phones, voice and email have made vague the line between life and work.  These realities decrease the amount of time that the average person is able to devote to wellness and health pursuits, and yet staff members are predicted to be at top performance when at work.

A current study conducted by the American Association of Occupational Health Nurses observed that workplace wellness or Workplace Wellness Programs are efficacious in helping staff members to make beneficial health changes due to several factors such as convenience, environmental backing, and co-worker or social acceptance.  

What’s the Link between Wellness and the Workplace?

Programs and policies that reward healthy lifestyles can make a sizable difference on employee wellness AND have an effect on the organization’s bottom line.  Studies show that for each dollar invested by employers in Corporate Wellness Programs/wellness programs, there were savings from $1.49 to $4.91 with a median savings of $3.14*.  In organization terms, that’s more than a 3:1 minimum return on investment – a number that is difficult to ignore, and a best practice that ought to warrant serious consideration from employers.  In fact, a Corporate Wellness Program literature review posted in Health Promotion Practitioner Journal found:

   • 19 research studies observed a 28.3% decrease in sick time
   • 16 different studies shown a 5.6:1 ROI
   • 23 showed a 26.1% decrease in health care expenditures
   • 4 saw a 30% reduction in direct healthcare and workers’ compensation claims

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

• The United States Department of Health & Human Services, 2003

After cost, poor employee program engagement and inadequate talks and backing are listed as the greatest challenges for companies administering any health benefi t program.22

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

Businesses that only engage in the minimally required due process communication of a Company Health Promotion Program, however, do a disservice to the plan and the corporation.

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

Under the proposed rules, the four requisites to be a bona fide Company Health Promotion 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 ten percent to twenty percent of the total expense of employee-only coverage may be appropriate.
- The program must be reasonably designed to promote good health or prevent disease for individuals 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 Corporate Wellness Program standard (or for whom it is medically inadvisable to attempt to meet the Corporate Wellness 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: United States Department of Labor Employee Benefits Security Administration

As Northwestern Memorial’s Kathryn Krivy says, “The most fundamental failure in any Workplace Wellness 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 inform them of what’s going on.”

A properly implemented Worksite Health Promotion Program is designed to save a company more money with greater participation. Nevertheless, a company must match its focus on program design with an equally strategic investment in efforts to participate employees in the initiatives.

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

Says Motorola’s Saenz: “We share with employees 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 Health Promotion Programs. This transparency is necessary to keep reminding people the reasons for our behaviors.”

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

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

As noted earlier regarding PepsiCo’s HealthRoads, one strategy is for companies 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 workers and other stakeholders see the larger objectives of the Worksite Health Promotion Program, rather than focusing on isolated offerings.

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

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

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

Nonetheless, since Corporate Health Promotion Programs touch on potentially private health problems, it is significant communication remains positive and inclusive, while not pressuring staff members. Discussion of wellness problems should be voluntary, though companies 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.

———-

Even in an at-will employment environment, individuals are still guarded from discrimination (including wrongful termination) by virtue of belonging to a protected class. Before starting a Workplace Wellness Program, corporations need to be cognizant of the relevant legal restrictions and the potential impacts 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 employer is offering access to health clubs, it should make sure 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 provide on-Site Employee Wellness Programs whenever possible. This not only ensures equal access, but according to Northwestern Memorial’s Krivy, also expands participation.

Organizations must also be aware that particular health topics may disproportionately affect protected classes. Health Risk Assessments and any incentives and rewards put in place may must be personalized 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 programs need to be applied equally to men and women. A employer cannot set a weight goal for men and not for women, even though a employer 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 goals, restrictions and incentives/rewards need to be designed with age appropriateness. While older employees (or retirees and dependents) may inherently pose a higher health risk, their conduct must be evaluated 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 individuals with disabilities in the private sector, and in state and local governments. Similar to other workplace offerings, any Corporate Wellness Programs, such as a fitness center or health clinic, would have to make reasonable accommodations for employees with disabilities.

One area of equivocation is whether very overweight employees qualify as disabled. The issue is complicated because weight is caused by several factors (genetics, environment, behavior), some of which may be out of the employee’s control. Generally, for employees to qualify for disability based on weight, 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 rewards and incentives and program requirements provided, it likely would not affect the overriding implementation of behavioral-focused initiatives.

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

This legislation authorizes people to sue corporations 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 company for egregious or habitual violations.

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

• Health status
• Medical condition (including both physical and mental illnesses)
• 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

Nonetheless, because wellness programs may not incorporate healthcare treatment or be insurance related, and may instead be confined to behavioral initiatives, HIPAA’s nondiscrimination provisions do not fully 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, employers that comply with the measure will be viewed by the government as making a good-faith effort to avert discrimination in wellness programs.

Robust Employee Wellness 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 companies to discrimination lawsuits, disengaged staff members and detrimental public relations. Nonetheless, companies that make a good-faith effort to comply with current Medical Care-related laws, discover ways to involve staff members, and communicate strategically, will be able to minimize these risks while finding plenty of room to develop a creative and effective Employee Wellness Program.