Commentary: As the EEOCs proposed regulations for wellness programs remain under review for public comment until June 19, employers should not feel paralyzed in designing new wellness programs nor compelled to throw out existing ones.
The proposed guidelines are not final and subject to some revision, though the extent of any potential changes remains to be seen. In the meantime, program sponsors will best serve their organizations by applying the proposed rules practically while carrying on wellness programs for the benefit of their people. Heres what that means for you, whether you are creating a new program or scrutinizing your existing one:
If youre developing a wellness program:
Dont stop; design your program to comply with the proposed regulations. Youll cover all of your bases and have an opportunity to adjust incentives and other program components prior to your launch, or in your next re-enrollment period, should the rules be expanded.
Investing in, rather than holding off on, your employees health and well-being gives you the potential to realize measurable and meaningful payoff, including uncovering risk for preventable chronic disease. That can change lives.
If you already have a wellness program:
Proceed with caution; if your existing wellness program falls outside one or more of the proposed regulations, take note, but be practical before making sweeping changes until the rules are finalized. You should not rush to transform program elements including incentive designs until the new regulations are set in stone.
Its important to review your program design carefully and understand exactly where it departs from the proposed rules. Be ready to enact change if and when you need to. In the meantime, dont be in a hurry to throw out wellness tools that are engaging your members and supporting your mission; they could very well be permitted in your wellness toolbox at the end of the day.
Bryce Williams is CEO and president of HealthMine, Inc, a consumer engagement technology company.
