RAS
What does RAS stand for?
Reasonable Alternative Standard
Do companies need to provide an incentive for individuals who participate in the wellness program?
No - but the likelihood for participation with no incentive is very low.
How often do we need to send the EEOC disclosure to all eligible participants?
At least once per year.
HIPPA or HIPAA?
HIPAA - Health Insurance Portability & Accountability Act
How often must participants be given the opportunity to earn the best possible incentive?
Yearly
What types of programs require an RAS program?
Outcomes based programs
What type of Health Plan must an employer have in order to utilize HSA contributions as an incentive.
High Deductible Health Plan
We must communicate the RAS program any time we communicate the incentive.
What is the title for someone who can receive HIPAA and how do we document that?
Privacy Officer, and we document this on the contract. If we have a new privacy officer, we should update the privacy officer page.
Can a client require all employees to pay the highest premium rate without offering an opportunity for a better rate?
Yes, we don't recommend it and it would likely create a negative experience for employees, but technically they can do it.
What does a participant get for completing an RAS program?
The opportunity to earn the best possible incentive.
Fill in the blanks: The maximum incentive you can provide to employees is __% of ______.
30% of employee + employer contributions
Can we send an employee their results via email?
Yes, but only upon request and if we do, email must be sent securely. We do not charge for one off requests but if a client is asking for this on a mass scale, there will be a fee.
Only what is absolutely necessary. We do not need to send all identifiers, we do not need to send additional data more than what the client is asking for.
What are the pros of rolling over the prior year's incentives for the upcoming year?
Pro: Easy administration, no additional work for participants
How does the incentive payout work for participants who complete the RAS program?
They must receive the full amount, including what they may have missed. Company may provided missed payment in one lump sum or break out over remaining pay periods.
Can a company require an employee to pay for their RAS program?
No, the company must provide an RAS at no cost to the employee.
Do we recommend that employers mass communicate the RAS program to their employees?
That depends. If the groups is focused primarily on improving employee health, then yes because we know that RAS participation drives better health results. If the group is focused primarily on cost control, they probably don't want employees utilizing the program. Additionally, if we have sold an RAS program that generates revenue, let's enroll as many folks as possible.
If you think you have mishandled PHI, what should you do?
1. Get your supervisor involved immediately
2. If information was sent to the wrong person, reach out to them right away, ask them to delete and then delete from their deleted.
3. If necessary, get Ben and/or Dawn involved.
Can you provide different programs and incentives to participants at the same client?
Yes, however you must treat all similarly situated employees the same. This will be particularly important this year, especially if you have groups who were able to begin screenings and not complete them.
Can you implement deadlines for RAS programs, what is our recommendation?
Yes. If client is not actively communicating the program, we recommend a deadline one month after adjustments are made. If client is communicating program, recommend an earlier deadline so client has less back pay.
At what threshold does HC360 advise clients to report additional income for tax purposes when utilizing gift cards as an incentive?
What communication recommendations do we have for employees who are modifying their program, especially around incentives.
Communicate changes early and often so employees feel like they have enough time to make changes or get active to achieve goals. During this time, employees will likely be more understanding of sudden changes, but it is important to get out ahead of communications once decisions have been made.
If an employee calls or emails for assistance on behalf of their spouse and they have all of the identifiers ready to verify, how should you handle the inquiry?
Let the employee know that we are happy to help the spouse by they must reach out on their own for assistance. If the spouse is present on the phone call and gives verbal permission, you may then offer assistance.
What are the cons of rolling over the prior year's incentives for the upcoming year?
Con: No HC360 revenue, client still needs to do something for the individuals who didn't earn best incentive, we lose a whole year of momentum and essentially 'start over' again in 2021.