Workplace Wellness Programs GBA1

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Discuss the major wellness program policy objectives and resulting pronouncements/regulations made by the Equal Employment Opportunity Commission (EEOC), which was responsible for monitoring ADA and GINA compliance.

(a) ADA and GINA standards for wellness programs. In 2000, the EEOC issued enforcement guidance that a wellness program is considered voluntary under the ADA "as long as an employer neither requires participation nor penalizes employees who do not participate." In 2010, final regulations to implement GINA restated this definition of voluntary wellness programs. In 2014, EEOC brought enforcement actions against several employers that penalized workers who would not participate in wellness programs that included medical inquiries. One action involved an employer that used financial incentives to encourage participation. Employer groups expressed disagreement with these actions, urging that ADA should be interpreted to permit use of financial incentives similar to those authorized under ERISA/ACA. (b) ADA standards for wellness programs offered through a group health plan. In May 2016, EEOC issued final rules on regulations to reinterpret ADA standards for voluntary wellness programs. The rules require any wellness program that involves medical inquiries to be reasonably designed, as defined under the ERISA/ACA rule. The ADA rule also specifies a reasonably designed wellness program must not be designed mainly to shift costs onto employees based on their health. And if the program collects health information, it must also provide participants with their results, follow-up information, or advice designed to improve health or use collected information to design a program that addresses at least a subset of health conditions identified. In addition, two new standards relating to (1) financial incentives and (2) notices applied to wellness programs. (1) With respect to incentives, employers cannot deny eligibility for group health plan benefits or take adverse employment action, or retaliate against, intimidate, or threaten employees who refuse to participate in workplace wellness programs. The rule allowed use of financial incentives or in-kind incentives to promote employee participation in wellness programs that include medical inquiries. The maximum financial incentive was 30% of the total cost* (employer and employee share) of self-only group health plan coverage. The rules specified this limit applies to both health-contingent and participatory wellness programs. A wellness program is considered voluntary under ADA if the amount of an incentive offered for participation—alone or in combination with incentives offered for health-contingent wellness programs—did not exceed this maximum. The rule further specifies that incentives need not be conditioned on participating in the group health plan. For example, if an employer offered a wellness program but did not offer group health plan benefits, the maximum incentive would be determined using the cost for self-only coverage meeting certain criteria sold on an ACA marketplace. Finally, the rule specifies that wellness programs cannot condition the incentives on the individual's agreement to the sale, exchange, sharing, transfer or other disclosure of medical information or to waive confidentiality protections that would otherwise apply. (2) Notice requirements also applied to wellness programs that involved medical inquiries such as HRAs. Programs were required to provide workers notice of what information would be requested, how it would be used, and how the privacy and security of personal information would be protected. Notice requirements also applied to any workplace wellness program, either health-contingent or participatory, that involved medical inquiries. (c) GINA standards for wellness programs. In May 2016, EEOC issued a final rule to make similar changes in workplace wellness standards under GINA as under the ADA. The GINA wellness rule addressed the extent to which an employer could offer inducements to an employee's spouse to participate in its workplace wellness program. Inducements for the spouse to participate in a wellness program could be made without regard to whether the employer offers group health benefits to the spouse or whether the spouse participates in the employer's group health plan. Under GINA, genetic information is defined to include not only results of a genetic test, but health information about an individual's family members, including the spouse. The rule makes an exception to this definition and permits wellness programs to offer incentives to spouses to provide information about their own health status, though not about results of genetic tests. The rule does not permit workplace wellness programs to offer incentives for children of employees to disclose their genetic information or any other health information. The GINA wellness rule adopted the ERISA/ACA definition of a reasonably designed wellness program as modified by the ADA wellness rule. In addition, the GINA wellness rule amended the standard for voluntary wellness programs to permit a maximum incentive for the spouse to participate in the workplace wellness program. The maximum incentive applicable to the spouse was 30% of the cost* of self-only coverage offered by the employer, regardless of whether the spouse participated in the health plan. If the employer did not offer a health plan, the rule specified the type of ACA public exchange plan on which to base the maximum incentive. The rule also included the ADA rule requirement that wellness programs cannot condition incentives on individuals agreeing to the sale, exchange, sharing, transfer or other disclosure of their genetic information. * Candidate Note: This 30% maximum financial incentive level was later rescinded by the EEOC because of a federal district court ruling. The EEOC has expressed an intent to issue further guidance in the future.

What are the federal privacy standards that are applicable to workplace wellness programs?

(a) Federal privacy protections may also apply to personal information gathered under workplace wellness programs. The ADA establishes privacy standards for covered entities subject to that law— that is, employers with 15 or more workers. Covered employers are required to keep private all medical information that they may obtain about workers, whether such information is collected through a wellness program or gathered for other permitted employment-related purposes. Access to identifiable medical information is restricted and only need-to-know exceptions are allowed, such as for administering a health plan. Identifiable medical information must be kept securely and separate from other employment records. With respect to employer wellness programs, the EEOC rule reiterates that medical information obtained by the program may only be provided to the employer in aggregate terms that do not disclose or are not reasonably likely to disclose the identity of any employee. In case of a suspected violation of ADA privacy rules, individuals may file a complaint with the EEOC and/or initiate a private lawsuit. Similar privacy standards under GINA apply to genetic information. (b) Federal privacy protections under HIPAA also apply to some workplace wellness programs. Covered entities under HIPAA include most health care providers, health care clearinghouses and health plans, including group health plans sponsored by employers, but employers are not covered entities under HIPAA. As a consequence, HIPAA privacy rules do not apply to wellness programs that are offered directly by employers outside of a group health plan. Under HIPAA, a group health plan generally cannot disclose personal health information to a person's employer without that person's authorization, but a group health plan is permitted to disclose protected health information to the employer without authorization if the employer certifies to the plan that it will safeguard the information and not use or share it for any employment-related activity or in connection with any other benefit. In case of a suspected violation of HIPAA privacy rules, individuals may file a complaint with the U.S. Department of Health and Human Services (HHS); there is no private right of action under HIPAA. For a complaint involving a covered workplace wellness program, HHS would investigate and verify whether the plan had received the required certifications from the employer. If the group health plan had not obtained the required certification, HHS could seek civil monetary penalties. However, if HHS found that an employer had violated its promise to only use the information that it receives for permitted purposes, HHS could not pursue enforcement against the employer due to the agency's limited jurisdiction. (c) Interpretive guidance issued with the final ADA wellness rule notes that different privacy standards might apply to worksite wellness programs, depending on whether or not the program is offered as part of a group health plan. Under the EEOC rule, privacy standards established under the ADA will continue to apply to any ADA-covered entity. In addition, when a wellness program is part of a group health plan, its obligation to comply with ADA privacy rules will likely be satisfied by adhering to HIPAA privacy rules. (d) Under all three privacy standards, it is permissible for wellness programs to share participants' health information with their business partners for purposes of administering the program. Under the "reasonably designed" standard, for example, this could include sharing information with a business partner to market health-related products and services to the enrollee. In summary, the May 2016 EEOC rules for ADA and GINA supplemented existing wellness regulations under HIPAA/ACA and, in some cases, compliance with HIPAA/ACA did not guarantee ADA and GINA compliance. Specifically, HIPAA/ACA rules did not impose any incentive limitation on "participatory" wellness programs, while ADA and GINA rules did impose limits if such programs included health risk assessments (HRAs) or biometric testing. In addition, HIPAA/ACA rules apply only to those wellness programs offered with group health plans; ADA and GINA rules also applied to wellness programs that were "self-standing." That is, the final EEOC rules made it clear that for purposes of ADA and GINA, there was no distinction as to their applicability between wellness programs offered inside or outside of group health plans.

Discuss a.) the Americans with Disabilities Act (ADA) and the Genetic Information Nondiscrimination Act (GINA) and how they pose ramifications for voluntary workplace wellness programs, (b.) the rationale for EEOC's initial regulations and enforcement guidance regarding voluntary wellness programs, and c.) the finding of a federal district court regarding this guidance and its overall impact on EEOC's regulatory guidance.

(a) Questions about the permissibility of workplace wellness incentives under federal law are ongoing. Two federal employment nondiscrimination laws—the Americans with Disabilities Act of 1990 (ADA) and the Genetic Information Nondiscrimination Act of 2008 (GINA)—prohibit employers from making inquiries about employee health information or genetic information with limited exceptions, including through voluntary workplace wellness programs. (b) Initially, regulations and enforcement guidance defined voluntary wellness programs to be those that neither require participation nor penalize employees for nonparticipation. In 2016, new federal regulations issued by the Equal Employment Opportunity Commission (EEOC) redefined voluntary wellness programs to include those that impose financial incentives up to 30% of the cost of self-only coverage (or more than $2,100, based on the average cost of self-only group health plan coverage in 2019). The agency asserted that it did so to permit wellness program incentives consistent with those permitted under the Affordable Care Act (ACA), but that nonetheless "prevent economic coercion that could render provision of medical information involuntary." (c) A federal district court found that EEOC did not provide sufficient justification for its wellness program incentives limits, and ruled this change in the definition of "voluntariness" to be arbitrary and capricious. EEOC repealed the financial incentive provisions of its ADA and GINA wellness rules in December 2018. The Agency's regulatory agenda indicates further rulemaking on wellness is planned. Meanwhile, other provisions of the ADA and GINA wellness rules remain in effect for all workplace wellness programs that make disability-related inquiries or conduct medical examinations. Such programs must be "reasonably designed." Among other requirements, reasonably designed programs must: Provide employees with advanced notice clearly explaining what medical information will be obtained, How the medical information will be used, Who will receive the medical information, The restrictions on its disclosure, and Methods the employer/wellness program uses to prevent improper disclosure of medical information. In addition, programs must be reasonably designed to promote health or prevent disease.

What is the benefit to employees when employers foster a high level of financial wellness?

A high level of financial wellness gives employees the ability to make better, more informed decisions and manage a successful long-term strategy.

Does research conclude that workplace wellness programs effectively promote health and prevent disease?

Despite the prevalence of workplace wellness programs, numerous studies find limited evidence of their effectiveness in promoting health or preventing disease. There are considerable challenges with measuring the impacts of workplace wellness programs. First, healthier individuals are more likely to participate in wellness programs, making it hard to determine whether differences in health outcomes reflect program effectiveness or the people who elect to participate. Secondly, workplace programs come in many shapes and sizes, with many programs focusing more on health screening than health promotion programs.

Explain why customization is required when it comes to a successful financial wellness program and what employers can do to accommodate the varied needs of employees and implement a holistic approach.

Each employee has different financial priorities and obligations, so a successful wellness program requires solutions tailored to an employee's unique circumstances. This starts with digital engagement, interviews and examination of employees' pay and benefits records to establish a complete picture of their finances. The aim is to understand employees' goals when it comes to paying taxes, purchasing a home, establishing and maintaining good credit, health care, emergency preparedness, education costs, paying down debt, saving for retirement and other parts of their financial life. The second part of a holistic approach to financial wellness is teaching the concepts of good financial health and providing the right tools to act on that knowledge. This means employees need not only education, but also the opportunity to put this information into action. For some employees, this simply means using software to keep track of financial goals. For others, having a financial coach or advisor to review their finances and offer suggestions does more to keep them accountable and engaged with their goals.

In what ways should financial wellness programs be thought of like programs that facilitate health-related wellness?

Employer-based financial wellness programs usually are an addendum to other benefits programs. However, it is best to view the financial health of employees through the lens of other health and wellness programs that employers routinely offer. These services do not just take care of employees when they are sick, but also work to prevent sickness in the first place with fitness, smoking cessation, diet and lifestyle management programs. Financial wellness programs should work in the same way, offering holistic support and advice to employees so they can meet short-term needs while working toward long-range goals.

Do employers reap any benefits or advantages when their employees achieve a high level of financial wellness?

Employers feel the effects of their staff's financial health and reap certain benefits and advantages. Employees in stressful financial circumstances are less productive and less likely to remain at their jobs. Many researchers have documented these advantages. A study by Mercer found that 22% of employees report missing at least one day of work to handle financial problems, 15% reported spending at least 20 hours a month working on personal financial tasks at work, and a full 20% have had to resign due to financial stress. Additionally, according to the Journal of Occupational and Environmental Medicine, one day of employee absence costs businesses an average of $348 in lost productivity. From that angle, ensuring workers are free from personal financial stressors can boost a company's profitability. Unfortunately, many companies—including those polled for the report conducted by the Center for Financial Services Innovation—do not realize their need for a broader approach to their employees' financial fitness until workers become reliant on emergency EAP services. Such reliance increases the costs of these programs and jeopardizes the company's ability to sustain them.

Do large employers offering wellness programs to their employees generally provide incentives for their workers to disclose personal health information?

Employers that offer health risk assessments in their wellness programs increasingly use financial incentives to encourage workers to disclose health information. In 2019, almost a third (32%) of large firms offering health benefits offered incentives to complete a health risk assessment (HRA), compared to 14% in 2008. A small percent of large offering employers (7%) offer incentives to not only disclose health information but also to achieve biometric outcomes such as a target BMI or cholesterol level.

With the EEOC revisiting the issue of incentives in workplace wellness programs, are employers temporarily ceasing to collect employee health information and declining to utilize such information in determining the pricing of health coverage?

Federal law permits the collection of health information from workers through voluntary workplace wellness programs, and the EEOC has given notice it will revisit the issue of incentives in future rulemaking. How federal standards for wellness incentives will evolve remains to be seen. Even as standards evolve, though, most large employer wellness programs continue to collect personal health information, and most of these screening programs incentivize workers to provide it. When incentives are applied to the premium contribution for group health benefits, failure to participate in wellness programs can substantially increase the cost that workers would otherwise pay for their health coverage.

What are the three key benefits that a comprehensive workplace wellness program can produce over time?

Fewer absences Improved productivity Worker satisfaction and retention

How can savings from financial wellness programs be channeled into other productive uses to further enhance employee long-term well-being?

Financial wellness can help companies reduce unnecessary expenditures due to absenteeism, lost productivity and benefit cost overruns, allowing businesses to expand their benefit options to include: Programs that enhance money management skills and help employees create and build assets Newsletters and other periodic publications Investment, retirement, college, emergency and health care planning seminars Debt- and credit-related programs A more extensive list of benefits can also help businesses attract and retain top-notch staff, because financially content employees are more likely to stay with the company for the long haul. The road to financial health is an ongoing journey. Once financial wellness is near, both employees and employers have a role to play in its continued progress. Establishing and cultivating financial fitness requires individual persistence as well as a supportive environment with accessible, high-quality financial services. This will not only allow companies to realize benefits such as increased loyalty, higher productivity and lower costs—but enable employees to meet the challenge of balancing responsible living today with wise planning for tomorrow.

How can one succinctly conceptualize "financial wellness"?

Financial wellness means effectively managing your economic life. This simple concept encompasses many factors, including: Keeping spending within one's means Being financially prepared for emergencies Having access to the information and tools necessary to make good financial decisions Having a plan for the future.

In what ways can collected health information be used by employers, and are there uses of such information that are strictly prohibited?

Health information collected through reasonably designed wellness programs can be used to provide meaningful feedback or advice to employees about their health or risk status; health information collected through wellness programs can also be used, in aggregated form, to design effective disease management programs or treatments. However, the EEOC regulations specify that a wellness program is not reasonably designed if it exists mainly to shift costs from the employer to targeted employees based on their health or to simply give an employer information to estimate future health care costs.

The following six ingredients typically comprise a well-structured wellness program:

Health screenings When designing a workplace wellness program, it is important to establish a baseline measurement of employees' current state of health and a profile of their health-related behaviors. Two useful tools can accomplish this: (a) Health risk assessment (HRA): The health risk assessment is a confidential form, most often prepared and administered by an outside vendor, that employees fill out, answering questions about their health-related behaviors—everything from whether they wear seatbelts to whether they exercise regularly. After completion of the HRA, an employee is given a private report, summarizing the results and making recommendations for improved health. When potential problems are revealed—such as a regular smoker mentioning that exercise is too difficult because of constant fatigue and coughing—the HRA will not attempt to deliver a diagnosis. What it will do is encourage every employee to obtain preventive health services and possibly make individual recommendations to see a doctor, if someone's symptoms suggest a deeper problem. (b) Biometric testing. For more detailed health status results, many employers bring in a nurse or other qualified professional to collect biometrics—test results for blood pressure, body fat percentage, cholesterol levels and other risk factors. This information is gathered via various physical measurements as well as a blood sample (usually done through a finger prick). Though biometric tests are not diagnostic, they have been shown to be very effective at motivating employees to get necessary medical attention or sign up for health-related activities to improve their results. Educational and self-help tools Employers can help to ensure that their employees get the most accurate, up-to-date health news to dispel confusion and misperceptions. To get peoples' attention, employers will probably want to use a combination of formats. Popular choices include targeted emails or websites, printed newsletters and short seminars (i.e., "lunch and learns") with guest speakers. The idea is to give people multiple ways to encounter company health messages. Recording speakers is a good idea, too; that way, people who miss the talks can watch them later. As far as subject matter, a company's health education program might provide, for instance, recommendations on target heart rates and water consumption, summaries of reports and studies (for example, those linking smoking and obesity to certain diseases), healthy recipes and much more. There's no need to stick to straight health topics, either: Discussions about living a balanced life and tips on dealing with financial difficulties are also relevant to total wellness and may be included, depending on the company's culture. Organized activities Most wellness programs include some visible activities—often on site—that employees can actively join, such as group walking or back- safety classes. Employers can decide what activities to include based on various factors: employee interest, employee health needs and ideas offered by a wellness team. Individual follow-up and treatment If a number of employees are affected by a certain condition or habit, there is nothing wrong with holding on-site classes or other group activities especially for them. Such classes could focus on how to manage a particular chronic illness or live a healthier lifestyle—covering nutrition and stress management. Incentives Incentives and rewards—cash, movie tickets, discounts on medical care or gifts—have been shown to double worker participation. Many employers use a small incentive right at the start to motivate people to take an initial health screening. What is "small"? Think cash or cash value of $25 to $50. After that, employers might offer incentives for meeting short-term goals—for example, they might give something to everyone who walks ten miles or more within a two-week period. They might also offer more for longer term achievements—for example, to whoever accrues the most fitness points over a six-month period. A supportive environment If a company provides one message in its wellness materials but fails to follow through or provides contrary messaging through other actions, its employees will assume the wellness program is not taken seriously and is not a corporate priority. If, for example, the company is encouraging people to bike to work, it will need to have secure bike racks in place. This attention to detail must extend from top management down throughout the organization. If the chief executive officer (CEO) looks suspiciously at everyone who comes in late—despite the fact that they were at the gym, and the company provides flex time for this—its program will not flourish. Conversely, a CEO who stops smoking and invites people to go jogging during the lunch hour will motivate people more than any pamphlet or statistic ever can.

Explain the evolution of ERISA standards related to "health-contingent" wellness program incentives.

In 2010, the Affordable Care Act amended ERISA to permit group health plans to adopt wellness program incentives that vary a person's group health plan premiums or cost sharing based on their health status. Such programs are called health-contingent wellness programs. Some health-contingent programs provide rewards, such as premium discounts, to people who can meet certain health outcomes, such as normal weight or blood pressure. Others might identify people with health problems and then provide rewards if they participate in wellness classes or activities. In 2013, the Department of Labor (DOL) said health-contingent wellness programs can vary group health plan premiums or cost sharing based on health status and will not be considered to discriminate based on health status if they meet certain standards. Among these conditions are the following. (1) The reward amount is limited. (2) The maximum reward is 30% of the total cost (both the employer and employee share) of self-only group health plan coverage. (3) The maximum can be increased to 30% of the cost of family coverage if spouses and dependents are eligible to participate in the wellness program. (4) The maximum can be further increased to 50% if tobacco-related components are included in the wellness program. Health-contingent wellness programs also must be reasonably designed to promote health or prevent disease. Reasonably designed is defined as having a reasonable chance of improving health or preventing disease, not being overly burdensome or a subterfuge for discrimination, and not being highly suspect in the method chosen to promote health. By regulation, this is "intended to be an easy standard to satisfy . . . There does not need to be a scientific record that the method promotes wellness to satisfy this standard." In addition, reasonably designed health-contingent wellness programs must meet other standards related to providing notice to participants, providing waivers or alternative ways for participants to earn rewards, and making rewards available to participants at least annually. ERISA standards are different for participatory wellness programs. Under the DOL rule, wellness programs that do not base rewards or penalties on health status are called participatory wellness programs. Participatory wellness programs are not required to meet any of the five standards that apply to health-contingent wellness programs and generally are not considered to implicate ERISA nondiscrimination rules. However, the DOL rule notes that other employment discrimination laws, such as ADA and GINA as noted in the next question regarding EEOC rules, also apply and that being in compliance with the ERISA/ACA wellness program standards does not relieve employers from having to comply with other federal laws.

Do many large employers who sponsor wellness programs request that employees disclose any personal health information?

Most large employers ask employees to disclose extensive personal health information via a questionnaire, known as a health risk assessment (HRA), or through biometric screening (such as a physical examination or lab test), or both. In 2019, 72% of large firms that offer health benefits, employing 48 million covered employees, offered the opportunity to complete either an HRA, biometric screening or both.

Identify which federal laws deal with standards for protecting the privacy of personal health information.

The Health Insurance Portability and Accountability Act (HIPAA) establishes standards to protect the privacy of personal health information, including information that may be collected by some workplace wellness programs. The ADA and GINA also include certain privacy protections.

Does the affordability factor associated with wellness programs restrict their introduction to larger organizations? Explain.

The affordability factor associated with wellness programs does not restrict their introduction solely to larger organizations. In fact, many small and mid-sized businesses have been shown to be superior at creating a culture of wellness within the workplace. Also, there are many wellness initiatives that can be introduced for free that do not require the expenditure of monetary resources. Amongst possible free initiatives are the following: (a) Holding regular workplace stretch breaks (b) Organizing a walking program (often cited by employees as their favorite wellness activity) (c) Instituting policies against smoking at work (d) Organizing potluck lunches featuring healthy foods (e) Identifying on-site assets available for wellness programs (such as a nearby walking trail or a conference room suitable for wellness classes).

What is the primary goal of a wellness program, and what are key decisions that should be made when initially designing a workplace wellness program?

The primary goal of a workplace wellness program is to transform your workplace culture into one that promotes healthy living. In pursuit of this goal, certain initial key decisions should be made. Among these decisions are the following: Who is the program being designed for? Which health issues to address?

How are "financial wellness" and "financial security" related, and do most employer-provided financial services and benefits effectively integrate these concepts?

The underlying concept of financial wellness is financial security, one of the most common goals reported by employees across all sectors. However, a minority of employees surveyed report having access to the kinds of financial services and benefits that they feel would be the most helpful in attaining financial security. The Center for Financial Services Innovation echoes this sentiment in its research. Most employer financial health offerings consist of limited employee assistance programs (EAPs) designed for crises, comprising just a small part of an employee's total health benefits package. In many cases, these EAPs are not included in the benefits package at all.

What is the "normal" cost range per employee per year for an employer to sponsor a workplace wellness program, and what are the primary cost drivers when introducing a wellness program?

There can be great variability in employer spending to sponsor a workplace wellness program; nevertheless, the cost of workplace wellness programs typically ranges from $0 to $450 per employee, per year. When designing a wellness program, certain elements comprise the largest drivers of cost. The most significant drivers of cost tend to be incentives, equipment and outside service providers like consultants, counselors and gyms. The key is to formulate a budget in advance and then to determine the level of program offerings that can be facilitated with allotted resources. Sharing certain costs with employees is a popular strategy for small businesses, particularly for offerings like classes and memberships.

Generally, are wellness program incentives effective at inducing employee participation when these incentives reach a certain dollar level?

There is tremendous variation in employer incentives, but at some firms, wellness penalties can be a significant cost for covered workers. Participation in wellness screening programs is not high, even with incentives. An analysis of the Employer Health Benefit Survey found that at large firms with an incentive for completing a health risk assessment, 50% of workers complete the assessment compared to 31% at firms with no incentive. Most large employers (61%) say either that financial incentives are either "not at all effective" or only "somewhat effective" in encouraging employee participation in wellness programs, or they don't know whether incentives are effective. Workers may opt not to participate in wellness programs to protect the privacy of their health information, because they don't find the program convenient and/or for other reasons. To the extent that wellness program incentives trigger financial penalties for nonparticipation, workers may find them burdensome, as a legal challenge demonstrates.

Summarize three federal laws that directly address workplace wellness programs within the context of other broad rules that prohibit discrimination based upon health status.

Three federal laws directly address workplace wellness programs within the context of other broad rules that prohibit discrimination based on health status. The Employee Retirement Income Security Act (ERISA) prohibits discrimination by group health plans based on an individual's health status. ERISA makes exceptions for wellness programs to offer premium or cost-sharing discounts based on an individual's health status in certain circumstances. The Americans with Disabilities Act (ADA) prohibits employment discrimination based on health status and generally forbids employers from inquiring about workers' health status but makes an exception for medical inquiries that are conducted as part of voluntary wellness programs. Finally, the Genetic Information Nondiscrimination Act (GINA) prohibits employment discrimination based on genetic information and forbids employers from asking about individuals' genetic information, including information about family members' health status or family history. Like the ADA, GINA allows an exception for inquiries through voluntary wellness programs.

What is missing from employer initiatives to provide financial well-being to their employees?

What is missing from employer initiatives is a more comprehensive approach to financial well-being, one that helps employees build lasting financial strength and stability, leading to a more solid organization.


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