Managed Care

Workplace Wellness Programs – BA's or not BA's?

  • 1.  Workplace Wellness Programs – BA's or not BA's?

    Posted 01-20-2015 02:53 PM
    This message has been cross posted to the following eGroups: Chief Compliance and Ethics Officer Health Care and Managed Care .


    A 2-prong question with regard to workplace wellness programs.  Acknowledging that these programs come in many flavors, let's start with the assumption that we are talking about a program that is providing biometric data assessments (cholesterol & glucose screening, height/weight/BMI, etc) to participants, and subsequently reports that data in a cumulative, de-identified manner back to the plan sponsor.  Two questions:

     #1 - Is the Wellness Program provider a BA, or not?  (I realize there are implications regarding ERISA, MEWA's etc at play, but taking the question on its face...)

    #2 - Inasmuch as data that may impact a participant's cost sharing is being transmitted by the Wellness program to the plan sponsor - under 45 CFR 162, does this constitute an electronic transaction that would imply that that the wellness program is actually performing a covered transaction, making the wellness program a provider under this part?

    Amy Wolfgram, CPC, CPCO
    Compliance Coordinator
    Group Health Cooperative of Eau Claire

    2020 HCCA Managed Care

  • 2.  RE: Workplace Wellness Programs – BA's or not BA's?

    Posted 01-21-2015 12:59 PM

    In the past, this type of information could be utilized to determine rate setting because there would be more relevant data to determine claim risk.  Should there be a concern that even if Medicare rates could not be impacted, a vendor who furnishes products for the commercial or non-Medicare community may transfer risk to an unrelated population.  Perhaps I am missing the intent of the collection and sharing of this type of information outside of support on the individual participant and determining future programs. .


    Yvonne Ervin

    Director - Public Sector Plans & Corporate Compliance

    First Continental Life & Accident Ins Co./StarDent

    101 Parklane Blvd. Suite 301 

    Sugar Land, TX  77478

    Contact: 281.276.1033  Mobile: 832.277.5927 Fax: 832.532.4068


    2020 HCCA Managed Care