Does your wellness vendor adhere to a code of conduct?

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Every major organized human activity has its own code of conduct, even war. So why shouldn’t wellness?

A small group of thought leaders — Jon Robison and Rosie Ward of Salveo Partners, Ryan Picarella of Welcoa and myself — recently decided the wellness industry’s time has come. While I can’t speak for the others, the eureka moment for me was a national wellness award being bestowed upon a vendor whose program’s own data demonstrated employee harms, likely due to its admitted disregard of clinical guidelines. Further, its massive savings claims — implausible enough to begin with, especially given the increase in risk factors across their population — were contradicted by its own previous (and subsequently suppressed) published savings figures.

Even after I made these observations public, the award committee allowed the vendor to keep the award. I decided that rather than simply registering my disapproval of these ethical and analytical failures by both the vendor and the award committee, it would be more productive to proactively work to prevent this from happening again. Keep in mind that wellness vendors are completely unregulated, a uniqueness in healthcare. Hence it falls to ethical people in the field to enforce a minimal standard of performance via moral suasion, and a code of conduct seems like a good place to start.

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Our group convened and soon developed the language at the end of this posting. Indeed, the Code (expanded to include all employee health programs, not just wellness) almost wrote itself because the minimum ethical standards were so self-evident that the only debate was whether they were prescriptive enough. And yet, minimal though it is, meeting the do-no-harm threshold will certainly prove a stretch goal for many vendors, whose harms include crash-dieting contests and deliberate disregard of clinical guidelines.

Quizzify will become the first vendor in the employee health space to incorporate this language directly into its contracts, meaning that if we violate this code of conduct, the contract itself is in breach. Normally, Quizzify strives to offer program attributes that no other vendor can match, such as a 100% savings guarantee or Harvard Medical School affiliation. However, in this case, it’s just the opposite: We urge other vendors to do exactly as Quizzify is doing in their own contracts and join us in raising the ethical, analytical and clinical standards for this field.

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While vendors and self-owned or self-distributed health plans should take the lead, many will likely need nudges from others in the value chain. Specifically, brokers and consultants should insist that vendors they represent adhere to the code in their contracts.

Most importantly, responsibility rests on the employer. If your vendor is not willing to be held to a “do no harm” standard, it is time for you to find a new vendor.

Here is an example of a “wellness code of conduct.”

The Employee Health Program Code of Conduct: Programs Should Do No Harm

Our organization resolves that its program should do no harm to employee health, corporate integrity or employee/employer finances. Instead we will endeavor to support employee well-being for our customers, their employees and all program constituents.

Employee Benefits and Harm Avoidance

· Our organization will recommend doing programs with/for employees rather than to them, and will focus on promoting well-being and avoiding bad health outcomes. Our choices and frequencies of screenings are consistent with United States Preventive Services Task Force, CDC guidelines, and Choosing Wisely.
· Our relevant staff will understand USPSTF guidelines, employee harm avoidance, wellness-sensitive medical event measurement, and outcomes analysis.
· Employees will not be singled out, fined or embarrassed for their health status.

Respect for Corporate Integrity and Employee Privacy

· We will not share employee-identifiable data with employers and will ensure that all protected health information adheres to HIPAA regulations and any other applicable laws.

Commitment to Valid Outcomes Measurement

· Our contractual language and outcomes reporting will be transparent and plausible. All research limitations (e.g., participants vs. non-participants, the “natural flow of risk” or ignoring dropouts) and methodology will be fully disclosed, sourced and readily available.

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