HR Management & Compliance

Don’t Get Tripped Up by ‘Reasonableness’ and ‘Alternatives’ Requirements for Wellness Programs


Can’t join your workplace wellness activities due to a health condition? Sure you can, using the government’s accessibility rules for wellness programs. Here’s a primer. 


In yesterday’s Advisor, we looked at “benign discrimination” and “multiple plan” rules for wellness programs. Today, we look at the “reasonableness” test and the “alternative standard” requirement, and introduce a new, three-part wellness program.


Reasonableness Test


HIPAA (Heath Insurance Portability and Accountability Act) requires that programs offered on the basis of reaching or satisfying a health status factor satisfy a reasonableness test. There are three elements:


1. The program activity or requirement must have a reasonable chance of improving the health or preventing disease in participating individuals.
2. Participation must not be overly burdensome.
3. The program cannot be “highly suspect” in the method chosen to promote health or prevent disease.


These are not onerous requirements. After all, why would you invest in a program that wasn‘t likely to work? But be aware that if you are implementing wild and crazy ideas, which probably means anything outside the mainstream, your program could be challenged based on these factors.


Alternative Standard


HIPAA-covered wellness programs must also be available to all similarly situated individuals. Therefore, the law requires that a reasonable alternative standard be offered to anyone for whom it is either:


• Unreasonably difficult, due to a medical condition, for the person to satisfy the program’s regular standard, or


• Medically inadvisable for the person to attempt to satisfy the usual standard.


It is permissible for the employer to seek verification, such as a statement from the employee’s physician, in these situations.


The availability of the alternative standard must be disclosed in all plan materials that describe the program, but this is not necessary in documents that just mention the availability of a program without describing its terms.


The plan can individually tailor the standard for each employee on a case-by-case basis.
Suggested language is:


“If it is unreasonably difficult due to a medical condition for you to achieve the standards for the reward under this program, call us at [phone number] and we will work with you to develop another way to qualify for the reward.”




Corporate wellness programs show great ROIs. And as one expert noted, there’s little downside—even small improvements make a difference. Check out BLR’s comprehensive Workplace Wellness program—guidebook, newsletters, and PowerPoints updated quarterly—at no cost or risk. Read more

A New “3-Dimension” Tool to Build Your Wellness Program


Although, as you’ve seen, there are some prickly details to running a wellness program, there’s also the potential for great reward, both in physical and financial health.


Well-structured and well-run wellness programs often show an ROI of more than 300 percent—numbers that make the C-suite smile. But the key words are well-structured and well-run, because poorly designed programs just spin their wheels—no health benefit and no positive ROI either.


What are the keys to success?


            • Careful planning and structure
            • Ongoing attention
            • Keeping it fresh


With this in mind, our editors have prepared a new and unique 3-part program that has something for everyone—the people who authorize the program, the people who run it, and the people who participate. BLR’s all new Total Workplace Wellness Program includes these key elements:


Part 1—Wellness Guide.  This 350-plus-page guide shows you how to set up your program—from convincing management to implementing a workable plan to maintaining its effectiveness over time. It includes a vast collection of ready-to-use forms, handouts, and checklists that both structure your program and provide the metrics to prove its effectiveness to management’s satisfaction.




Check out BLR’s comprehensive Total Workplace Wellness Program at no cost or risk. Click here for

Part 2–Quarterly manager’s newsletter. Clearly-written, practical, up-to-the-minute info—the latest in wellness news, case studies of successful programs, and practical tips from the field on running an effective program.


Part 3–Interactive employee PowerPoint® sessions. Employees stay engaged with these interactive training kits. Each focuses on a key wellness topic such as Managing Stress, Healthy Aging, and many more.


PLUS along with your quarterly newsletter, you also receive quarterly updates for both the guidebook and the PowerPoint training sessions—so there’s no trouble keeping your program humming with fresh ideas and proven suggestions.


If you’d like to examine the Total Workplace Wellness Program on a no-cost, no-obligation basis for 30 days, we can arrange for you to do so. Click here and we’ll be happy to set it up.

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