:: Paul Rauseo ::

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Money is a basic motivator! Read on!

Every person has different motivations for working. The
reasons for working are as individual as the person. But, we all work because
we obtain something that we need from work. The something we obtain from work
impacts our morale and motivation and the quality of our lives. Here is the
most recent thinking about motivation, what people want from work.

Work IS About the Money

Some
people work for love; others work for personal fulfillment. Others like to
accomplish goals and feel as if they are contributing to something larger than
themselves, something important. Some people have personal missions they
accomplish through meaningful work. Others truly love what they do or the
clients they serve. Some like the camaraderie and interaction with customers
and coworkers. Other people like to fill their time with activity. Some workers
like change, challenge, and diverse problems to solve. Motivation is individual
and diverse.

Whatever
your personal reasons for working, the bottom line, however, is that almost
everyone works for money. Whatever you call it: compensation, salary, bonuses,
benefits or remuneration, money pays the bills. Money provides housing, gives
children clothing and food, sends teens to college, and allows leisure
activities, and eventually, retirement. To underplay the importance of money
and benefits as motivation for people who work is a mistake.

Fair
benefits and pay are the cornerstone of a successful company that recruits and
retains committed workers. If you provide a living wage for your employees, you
can then work on additional motivation issues. Without the fair, living wage, however,
you risk losing your best people to a better-paying employer.

In
fact, recent research from Watson Wyatt Worldwide in The Human Capital Edge:
21 People Management Practices Your Company Must Implement (or Avoid) to
Maximize Shareholder Value, recommends, that to attract the best employees,
you need to pay more than your average-paying counterparts in the marketplace.
Money provides basic motivation.

Got Money? What’s Next for Motivation?

I’ve
read the surveys and studies dating back to the early 1980s that demonstrate
people want more from work than money. An early study of thousands of workers
and managers by the American Psychological Association clearly demonstrated this.
While managers predicted the most important motivational aspect of work for
people would be money, personal time and attention from the supervisor was
cited by workers as most rewarding and motivational for them at work.

In a
recent Workforce article, “The Ten Ironies of Motivation,”
reward and recognition guru, Bob Nelson, says, “More than anything else,
employees want to be valued for a job well done by those they hold in high
esteem.” He adds that people want to be treated as if they are adult human
beings.

While
what people want from work is situational, depending on the person, his needs
and the rewards that are meaningful to him, giving people what they want from
work is really quite straight forward. People want:

·        
Control
of their work inspires motivation:
including such components as the ability to impact decisions; setting clear and
measurable goals; clear responsibility for a complete, or at least defined,
task; job enrichment; tasks performed in the work itself; and recognition for
achievement.

 

·        
To
belong to the in-crowd creates motivation: including items such as receiving timely information and
communication; understanding management’s formulas for decision making; team
and meeting participation opportunities; and visual documentation and posting
of work progress and accomplishments.

·        
The
opportunity for growth and development is motivational: and includes education and training; career paths; team
participation; succession p[planning; cross-training; and field trips to
successful workplaces.

·        
Leadership
is key in motivation.
People want clear expectations that provide a picture of the outcomes desired
with goal setting and feedback and an appropriate structure or framework.

Recognition for Performance Creates Motivation

In The
Human Capital Edge, authors Bruce Pfau and Ira Kay say that people want
recognition for their individual performance with pay tied to their
performance. Employees want people who don’t perform fired; in fact, failure to
discipline and fire non-performers is one of the most demotivating actions an
organization can take – or fail to take. It ranks on the top of the list next
to paying poor performers the same wage as non-performers in deflating motivation.

Additionally,
the authors found that a disconnect continues to exist between what employers
think people want at work and what people say they want for motivation.
“Employers far underrate the importance to employees of such things as
flexible work schedules or opportunities for advancement in their decision to
join or leave a company.

“That
means that many companies are working very hard (and using scarce resources) on
the wrong tools,” say Pfau and Kay. (p. 32) People want employers to pay
them above market rates. They seek flexible work schedules. They want stock
options, a chance to learn, and the increased sharing of rationale behind
management decisions and direction.

What You Can Do for Motivation and Positive Morale

You have much information about what people want from
work. Key to creating a work environment that fosters motivation are the wants
and needs of the individual. I recommend that you ask your employees what they
want from work and whether they are getting it. With this information in hand,
I predict you’ll be surprised at how many simple and inexpensive opportunities
you have to create a motivational, desirable work environment. Pay attention to
what is important to the people you employ for high motivation and positive
morale. You’ll achieve awesome business success.

Susan M. Heathfield

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Major influences on employee attendance: A process model.

Presents a model of employee attendance in work organizations based on a review of 104 empirical studies. It is suggested, based on the literature, that attendance is directly influenced by 2 primary factors: (a) attendance motivation and (b) ability to come to work. Attendance motivation, in turn, is largely influenced by satisfaction with the job situation and various internal and external pressures to attend. The model attempts to account for both voluntary and involuntary absenteeism. Moreover, the model argues against earlier assertions that absenteeism is principally caused by job dissatisfaction and that absenteeism and turnover share common roots. Available literature is largely consistent with the model but not sufficient to validate it. (3 p ref) (PsycINFO Database Record (c) 2012 APA, all rights reserved)

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Managing Multidimensional Organizations

Professional businesses today are structurally complex organizations with
many senior people overburdened by time-consuming and often conflicting roles.
Professional businesses often have some combination of
  • Business unit
  • Geographic markets or offices
  • Division or department
  • Product line/service offering
  • Industry group
  • Key account team
  • Committees (recruitment, training)
  • Task force or project team (service innovation, new offerings)
    Each of these organizational groupings can, and does, intersect with
    duplicated missions, overlapping membership, and common resource pools to draw
    upon.
    We frequently hear comments like this from members of management:
    “It’s not at all clear what each of these groupings should be responsible for
    and how their activities should be coordinated and evaluated. If you are a key
    player in this organization, you can spend an inordinate amount of time in
    meetings. There has got to be a better way to organize for effective
    operations!”
    There is a better way, but the way professional businesses organize
    and manage has not kept up with their increasing complexity. Eventually — we
    think sooner rather than later — this will significantly impede their continuing
    success.
    Not only do modern companies have more “types” of organizational groupings
    than in the past, but these groups now have broader responsibilities than the
    simple “generate and serve clients” goals of the past. To survive and flourish,
    individual groups within today’s organizations must be accountable for client
    loyalty, knowledge transfer, development of their people (junior and senior),
    and many other “balanced scorecard” items.
    To make it all worse, many of these groups are composed of people who,
    because of geographic dispersion, do not see each other regularly face-to-face.
    They have to operate as members of a “virtual” organization. Many would not even
    recognize some of the people in their own operating groups, with whom they have
    to interact regularly.
    As Marcel Goldstein, of the global public relations firm Ogilvy, wrote to
    us:
    “The modern-day professional business lacks much formal structure, at least
    when compared with manufacturers, government agencies, and other organizations.
    This is a great asset, as it allows the flexibility, creativity, and autonomy
    necessary to adapt to client needs. It can have a darker side though:
    inefficiency, confusion, and process breakdowns.
    “In many professions, clients are demanding cross-practice cooperation. But
    do we have the right structures and personal skill sets to successfully manage
    the integration of specialty expertise?
    “The highly matrixed professional business turns downright chaotic during
    times of great change: acquisitions/mergers; technology disruptions; and
    transitions to integrated, cross-functional service delivery.
    “Many professional businesses engage in acquisitions of great fanfare, only
    to have their value left unrealized by political undermining. In my experience,
    traditional manufacturers with structured, hierarchical management execute
    acquisitions with far less confusion and resulting paralysis.
    “We need structures that don’t squash flexibility and creativity but minimize
    inefficiency and confusion. We need help building the personal skill sets needed
    to manage ourselves and each other in these environments, especially during
    times of great change.”
    We certainly would not profess to have answers to all these complex issues.
    However, we believe that there are five perspectives that must guide any review
    of a firm’s or company’s structure.

    Imperative 1: Examine Structure, Process, and People

    The solution for an individual firm must always address three perspectives in
    any organizational review:
    1. structure (how we are formally organized);
    2. processes (how different types of decisions are to be made
      and how conflicts and trade-offs are to be resolved);
  1. and people (appointing the right individuals to play the
    complex roles that will make it all work).

    No one dimension will solve the problem: all three must be examined. However,
    we suspect that the importance of these three elements in the solution may be
    first, people; then processes; then structure.

    Imperative 2: Choose the Right Group Leaders

    Many organizations believe, as we do, that selecting the right leaders (and
    having enough of them) is more important than structure or process.
    Peter Kalis, managing partner of law firm Kirkpatrick & Lockhart, states
    the view forcefully:
    “Structure and process — while as essential to a law firm as a skeleton and a
    nervous system are to a human — are prone to ossification and thus are
    fundamentally at war with the dynamism of the marketplace. People, on the other
    hand, are not. We try to elevate the empowerment of our people over the
    organizational niceties of structure and process except to the extent that those
    structural and process features work to empower our people.”
    Choosing the right people for leadership positions was always important, but
    is even more critical in complex organizations. Consider just some of the (newly
    important?) skills that today’s group leader probably must have:
    • The ability (and interest) to motivate and influence people they never see
      in person
    • The ability to delegate and trust others to manage important relationships
    • The ability to play a “linking-pin” role, simultaneously thinking about the
      overall good of the firm while taking care of the needs of the units they are
      responsible for
  • The ability to manage people who have core disciplines other than the one in
    which the leader was specifically trained

    It has always been true that effective management required a complex mix of
    social, interpersonal, psychological, political, and emotional skills on top of
    the high intelligence and technical skills necessary to rise to the top. We
    believe that as organizations become more complex, possession (and development)
    of these so-called soft skills must play an ever-more-important role in
    influencing who is selected to perform managerial or leadership roles.
    Unfortunately, such considerations do not always play a dominant role in
    selecting group leaders. It is a common syndrome that all initiatives (client
    team, industry, geographic, functional, etc.) are seen as important, so the same
    senior people always end up on all the committees, often based on considerations
    other than managerial aptitude or even orientation.
    As a result, it is somewhat hit-and-miss as to whether the right people get
    selected for these roles, their mandate is clear, their performance as leaders
    gets discussed and evaluated, and whether they receive any assistance or
    guidance in learning how to perform their roles.
    Not only does this hurt the organization by (possibly) leading to less
    effective team leadership, but it’s not clear that it is wise to consume the
    limited time of valuable people by asking them to manage and/or get involved in
    everything. This is simple economics — a valuable resource should always be
    focused on its highest and best use.

    Imperative 3: Establish Mandates for Each Group

    Even if you have an ideal structure, there will always be problems with
    coordinating cross-boundary resources and dealing with conflicting priorities.
    You cannot make all cross-boundary issues go away by simply redesigning the
    boundaries.
    Beyond structure, companies must ensure that each group has a clear mission
    (or mandate) that is understood by those inside and outside the group.
    In our experience, many firms launch new business units, various committees,
    or project teams with ambiguous charters and then leave it to powerful (or
    not-so-powerful) group leaders to determine through negotiations over time
    precisely how the groups will interact.
    The case for doing this rests on the idea that internal competition
    is the inevitable result of shifting external market forces influencing each of
    the organization’s groups differently and that a flexible approach to the
    responsibilities and interactions of groups is an efficient way of responding to
    these external market forces.
    However, we believe that failing to discuss and resolve the issues of group
    responsibilities (and how groups will interact and resolve conflicts and
    trade-offs) rarely results in optimal outcomes.
    Under such an approach, power rather than principle determines group goals
    and how groups will interact, and this leads to lesser performance. Resolution
    of conflicting goals and clear, agreed-upon guidelines for decision making over
    trade-off situations must be determined in advance.
    We also believe that organizations must stop treating all groups alike, which
    many unfortunately do, for administrative convenience. It is possible to use
    different types of groups for different things: lots of little teams for
    client-level relationships or one large central group for financial and
    administrative services.
    A large, growing, and complex firm doesn’t have to be (in fact, can’t be)
    made up of units that have similar roles, look alike, have the same targets, and
    are managed in the same way. We discussed specific procedures for setting group
    goals and mandates in our book First Among
    Equals     (Free Press, 2002).
    In making all this work, it is almost better to stop thinking of permanent or
    semi-permanent “departments” and to begin to use the language of “teams.” There
    is a great deal of evidence that organizations work better when people feel that
    they are volunteers self-selected to small mission-oriented teams.
    This is not just a matter of making people “feel good.” It has always been
    true that winning professional service firms succeed most by designing their
    organizations from the bottom up — through the voluntary enthusiasm of
    individuals. You’ll be better off with a messy set of teams filled with
    enthusiasts than you will with a logically correct set of groups filled with
    good citizens.
    As Ben Johnson of law firm Alston & Bird remarked:
    “One problem is that too many ‘leaders’ are afraid to create more energy than
    they can control. I tell people I’d rather have created more energy than I could
    control than not created any energy at all. Here’s to structural complexity!
    Here’s to dispersed leadership!”
    On the other hand, it is also important that firms clarify the roles and
    responsibilities of group leaders and avoid the balkanization of the
    organization that can come from letting group leaders think that they are
    responsible only for their groups.
    Peter Friedes, the former CEO of human-resources consulting firm Hewitt
    Associates, had this to say:
    “I had 15 or so managers reporting to me. So I needed them to not be pulling
    the firm in different directions. One practice I had was to remind all those who
    reported to me that part of their role was to have my CEO perspective in
    managing their group. They were not to just be an advocate for their group or
    their people. They had to have a ‘whole entity’ view.”

    Imperative 4: Clarify Agreements Within the Groups

    Whether you are managing a division, a key client team, or a limited-scope
    task force, every group needs to have a very clear understanding of what “team
    membership” implies. As a matter of practicality (although not, alas, reality in
    some firms) there also needs to be a limit on the number of teams one person can
    join (and the number of roles one person can play).
    For teams to work, there need to be clear, explicit guidelines (even rules of
    engagement) that team members have agreed to observe. Clarifying team members’
    rights and obligations can go a long way toward becoming more efficient and
    effective. (Even as simple a rule as “You must do what you said you were going
    to do” would transform some organizations and save a lot of wasted meeting and
    planning time.)
    The need for such agreements, while always wise, has become ever more
    critical in a virtual world. As Harry Truehart, chairman of law firm Nixon
    Peabody, observed, “Getting people and procedures that facilitate effective
    ‘management at a distance’ is the biggest challenge in making groups work.”
    We believe that if far-flung groups made up of many autonomous individuals
    are to make cohesive decisions over time, then it is necessary that the group
    members agree in advance the principles on which they will base their decisions
    — the guidelines the group members agree to follow. Only with such an agreement
    in place can a decentralized organization make consistent decisions.
    Part of the solution, may involve thinking of (and formalizing) different
    levels of team membership. For example, levels of “team membership” might
    include (i) full decision rights — possible called Team Leadership, or (ii)
    right to be consulted — called team membership or (iii) right to be kept
    informed — called team affiliation. (These are examples only.)

    Imperative 5: Recognize Shifting Priorities in Structural Design

    Structural changes alone will not resolve conflicting priorities and
    competing demands for resources, but structure does nevertheless matter. The
    evolution of professional-service firms over time suggests that some structural
    approaches do work better than others. Most successful global firms, in a broad
    array of professions, have tilted the importance of their different
    organizational “axes.”
    For some time, there has been a general trend to make the target client
    industry the most important (and organizationally powerful) grouping. This has
    been driven by clients repeatedly telling their vendors and providers that they
    had better get to know and understand the client’s business.
    Next in authority and emphasis comes the specifically targeted client (or key
    account) team. Well-orchestrated client teams are the only answer to making
    seamless service across geography and product/service offerings a reality. Don
    Lents of law firm Bryan, Cave notes, “It is my sense that there is a growing
    focus on client teams and the need for such teams to be front and center in the
    thinking of firms.”
    Third, and with increasingly less power and responsibility inside most
    organizations, are the traditional product or service-line groups built around a
    focused technical specialty or discipline. Companies need to have highly focused
    and skilled technical people, but few are still primarily organized that way.
    Finally (and this is a huge revolution from the past), the trend has been to
    make geography the least important and powerful dimension of the complex matrix.
    In the past, the office head (or country head in mega firms) was the source
    of all resources and the arbiter of last resort. Today, in many organizations, a
    geographic head may preside over a location whose people all belong to groups
    headed and “controlled” by a powerful leader located elsewhere.
    This is not meant to denigrate the role of the geographic leader. As Bob Dell
    of law firm Latham & Watkins points out:
    “Having the right leader in an office can be extremely effective in
    facilitating the success of all the other groups therein. There seems to be
    something about physical presence combined with a leader who is perceived as
    less biased toward any group that can be very powerful in resolving competing
    demands.”

    Moving Forward

    We believe that there is a distinct process that firms need to go through to
    find their own customized solutions to managing a complex organization.
    The steps are these:
    First, assess the perception of “pain and difficulties” felt by the current
    organization, to determine people’s appetite for considering changes. This will
    usually require a process of interviewing key players across the firm. No change
    can be made unless there is a keenly felt sense of either pressure or
    opportunity.
    Next, it will be necessary to collect and assess the evidence as to how well
    the organization and its components are currently performing and interacting. In
    a recent issue of The McKinsey Quarterly (2006, number 3), Cross,
    Martin, and Weiss described a detailed and powerful methodology for “mapping the
    value of … collaboration.”
    Even if the approach is not this thorough, there will need to be an
    investigation of current organizational functioning, including not only an
    in-depth view of financials, analyzed according to numerous perspectives, but
    also an analysis of external evidence (including, perhaps, input from selected
    clients) and internal structural frustrations and performance inhibitors.
    It will be necessary to examine whether reward systems are in line with
    organizational objectives and whether profit-center accounting systems are
    contributing to a balkanization of the organization.
    At the other extreme, it would be worth examining whether the organization is
    currently being held together and energized by sharing in what is sometimes
    referred to as an “overarching purpose” or shared values. This is an approach to
    organization that is often fervently preached but rarely achieved.
    Next, in any organizational review, would be the need to design and implement
    a process to generate commitment to re-examine organizational structures and
    processes and explore the major alternatives (including possibly re-constituting
    key groups). Any redesign, must, of course, ensure continuity of strategy
    formulation and implementation through the organization.
    Finally, it will be necessary to examine, consider, and implement methods for
    the development of special managerial skills and competencies as well as new
    metrics that may give better indications of the organization’s functioning and
    response to external forces or internal pressures.
    It may also be necessary to design a process to get the organization to
    recommit to a clarified sense of purpose, values, and “rules of membership”: —
    the principles and practices that people must follow to remain members in good
    standing of the organization.
    Of course, to make any of this work, there is a need for key players to be
    willing to let other people decide some things even when they’re not there — a
    situation which does not exist in many companies and firms!
    We do not mean this to be a throwaway line. To effect real change,
    organizations must not try to establish “theoretically correct” structures and
    processes but must have honest discussions among powerful players about the
    types and nature of the firm’s group processes that would, in fact, be
    honored.
    We have seen too many firms go through the motions of putting in place what
    appear to be sensible organizations, when everyone knows that certain key
    players will not adhere to the policies that have been adopted.
    We’re not idealists here — we recognize the realities of the need to
    accommodate personalities and special situations. But we also do not believe
    that progress is made by pretending or obtaining “false consent.” That is why
    organizational solutions must be custom-designed for each firm and need to be
    the result of a comprehensive review, not, as is so frequently the case, the net
    result of an accumulation of a series of incremental changes driven by short-run
    pressures.

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Risk Analysis: How To Value Your Human Capital 2012

In order to effectively manage risk and prioritize decision and resource making decisions, it is vitally important that planners determine the value of the asset first. In this article we are going to look at the issue of accurately valuing human capital. This process will include measuring key elements such as remuneration, contribution, revenue attraction, benefits and travel value.

By the end of this article you will know how to accurately value one of the most valuable but likely least understood asset classes, your people or human capital. This improved approach will reduce your asset vulnerability, enhance safety and increase productivity through reduced wastage and inaccurate planning.

Introduction

Why is it that almost all other asset classes have a specific value and investment/insurance calculation but human capital does not?

If you own a building, a car or even your home contents you have to declare a value to your insurance provider and then based on your overall percentage of contribution you determine if the value of insurance, as one of many means of protecting that asset, is worth the investment for full or partial loss in the event of an incident. Why do companies not do this for human capital? Does your company know the exact cost of each human capital unit on a temporary or permanent loss basis? If not, how are you basing your risk management and resources allocation decisions?

The following will address the key elements for inclusion to accurately value your unit cost per human capital element to make a more informed investment decision as to appropriate risk management options for your human capital.

Remuneration and Benefits

Many human resource (HR) departments have graduated scales or processes for measuring the position of an individual within a company such as E1, F3, B9 and so on. However, these are often exclusively only derived from salary/remuneration and benefits calculations which in reality constitute only a small percentage of the overall “value” associated to any one person.

While you can harvest this information or compile your own from scratch, remember it is only part of the final assessment.

The final number should include salary, benefits, holidays, cost of living allowances, fringe benefits, perks, shares and any other basic payments made on a regular basis as per their position and function within the company.

Final money paid to the individual is one matter but a more compelling and vital calculation is just how vital is their contribution to the company or product/service?

Contribution and Utility

Each department is different but in essence they can be viewed as a cost center or profit center. The question is which one? The unit valuation of any one person is also inclusive of their contribution to the company based on role and expertise.

Your critical processes may include production, billing and executive management therefore they have a higher priority within your business continuity planning and attract a greater weighting on the contribution scale.

On the other hand, back office activity such as cleaning, administration and marketing may not be as high a priority in a critical situation therefore attract a lower overall contribution value.

The cumulative score for both salary and contribution is compiled and added to the next component, replacement and recruitment.

Replace and Recruit

You know how much it costs to recruit, train and even replace a senior executive and other high yield human capital. Some forecasts for a failed international assignment put this in the vicinity of USD$150,000 per executive position. To accurately calculation the loss and value of your human capital as an asset class you need to include replacement and recruitment.

The reason this is necessary is that if your processes are inadequate and your protection of your human capital assets are poor you can expect too loose (injury, strike, absence, avoidance and even death) some of your people or at best reduce their availability (sickness, absence, recovery) at various times or in single catastrophic events.

The replacement and recruitment value is then added to the proceeding categories before moving to the next area, revenue attraction.

Revenue Attraction Specific To Human Capital

These are your money or income producing talent. They could be sales people, production personnel or academics but those that attract revenue on behalf of the company, product or services.Human Capital Distribution

Revenue attraction is a very important, and none-the-less ignored, component for your human capital calculation because it can be sizable in number and catastrophic in lost earnings if the person/s in question are not available for any period of time.

If you have a sales team whereby your entire revenue figure is derived from just 1 or 2 people then the value attributed to those people is much, much higher than others in the same department or even in the entire company.

While the number may fluctuate over the course of the year, it needs to be an annual figure (consistent with all the other calculations) but must also be reviewed/amended annually also.

Revenue attraction is typically a single element if fixed earnings are known in a static location but you may need to include an additional factor for those that travel to close or generate business as this figure can also be sizable if forgotten or overlooked.

Travel Value

Many senior executives and revenue all-stars travel regularly. This travel element therefore warrants inclusion or calculating too.

If for example, a new business opportunity presents in the vicinity of $10 million and a team/single person is dispatched to close on this opportunity then this occasional business figure needs inclusion as it is underpinned once again by key human capital exposure.

Rarely do companies consistently value such business travel activities but it is both lucrative for the company and costly should it fail or loss of human capital access is experienced.

Travel value is the final and optional component to a baseline evaluation of human capital within an organization. Companies vary wildly as to their human capital distribution but this final number is far from an even bell curve result either.

Time Loss

Now you have your final number you can determine your time loss component on an hourly, daily, weekly and even annual basis. You can now appreciate why generic “one policy fits all” approaches don’t work. This is largely due to the fact that your policy is aimed at 100% of the workplace population but 80% of your human capital value comes quite possibly from less than 10% of your overall employees/staff. 

This time loss calculation (sometimes used in single and annual loss expectancy planning) now becomes the foundation of your decision making process or your risk based decision planning. Use it, at a group and individual level to truly determine the value of the task and asset and plan accordingly.

If you have a situation where you have millions at risk and you’re economizing on a few dollars, re-evaluate your strategy. Alternatively, if you have a relatively small asset exposed and your expending millions based more along the lines of fear, uncertainty and doubt, then go back to the start of this article and do your calculations and question your sensibility in this latter approach.

Conclusion

Now you can appreciate the necessity for a more consistent methodology for valuing your human capital. They’re an asset, treat them as such. Use this consistent and effective approach to remove the emotional or abstract processes that are likely to be plaguing your organization.

You now have the various elements such as remuneration, contribution, revenue attraction, benefits, replacement, time loss and travel value to make a much more accurate assessment as to the true nature and value of your asset. Compare this to your other asset classes such as buildings, product, information and you may get a very rude shock as you have been apportioning your attention and concerns in totally the wrong area.

Make risk based decision on understanding all the factors, inclusive of the true value of the asset at risk. Overcome historical avoidance or HR dominant processes to value the asset and most importantly the true cost of permanent or temporary access denial of such asset/s.

T. Ridley

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OBAMACARE: Wellness Program Compliance Audit

WELLNESS PROGRAM CHECKLIST

Use the following questions to help determine whether the plan offers a program of health promotion or disease prevention that is required to comply with the Department’s final wellness program regulations and, if so, whether the program is in compliance with the regulations.

A. Insert the first day of the current plan year: _______________________________.

Is the date after July 1, 2007? …………………………………………………………… Yes No

The wellness program final rules are applicable for plan years beginning on or after July 1, 2007.

B. Does the plan have a wellness program? …………………………………………… Yes No

A wide range of wellness programs exist to promote health and prevent disease. However, these programs are not always labeled “wellness programs.” Examples include: a program that reduces individual’s cost-sharing for complying with a preventive care plan; a diagnostic testing program for health problems; and rewards for attending educational classes, following healthy lifestyle recommendations, or meeting certain biometric targets (such as weight, cholesterol, nicotine use, or blood pressure targets).

TIP: Ignore the labels – wellness programs can be called many things. Other common names include: disease management programs, smoking cessation programs, and case management programs.

C. Is the wellness program part of a group health plan?………………………… Yes No

The wellness program is only subject to Part 7 of ERISA if it is part of a group health plan. If the employer operates the wellness program as an employment policy separate from the group health plan, the program may be covered by other laws, but it is not subject to the group health plan rules discussed here.

Example: An employer institutes a policy that any employee who smokes will be fired. Here, the plan is not acting, so the wellness program rules do not apply. (But see 29 CFR 2590.702, which clarifies that compliance with the HIPAA nondiscrimination rules, including the wellness program rules, is not determinative of compliance with any other provision of ERISA or any other State or Federal law, such as the Americans with Disabilities Act.)

D. Does the program discriminate based on a health factor?………………….. Yes No

A plan discriminates based on a health factor if it requires an individual to meet a standard related to a health factor in order to obtain a reward. A reward can be in the form of a discount or rebate of a premium or contribution, a waiver of all or part of a cost-sharing mechanism (such as deductibles, copayments, or coinsurance), the absence of a surcharge, or the value of a benefit that would otherwise not be provided under the plan.

Example 1: Plan participants who have a cholesterol level under 200 will receive a premium reduction of 20%. In this Example 1, the plan requires individuals to meet a standard related to a health factor in order to obtain a reward.

Example 2: A plan requires all eligible employees to complete a health risk assessment to enroll in the plan. Employee answers are fed into a computer that identifies risk factors and sends educational information to the employee’s home address. In this Example 2, the requirement to complete the assessment does not, itself, discriminate based on a health factor. However, if the plan used individuals’ specific health information to discriminate in individual eligibility, benefits, or premiums, there would be discrimination based on a health factor.

If you answered “No” to ANY of the above questions, STOP. The plan does not maintain a program subject to the group health plan wellness program rules.

E. If the program discriminates based on a health factor, is the program saved by the benign discrimination provisions?…………………………………………………….. Yes No

The Department’s regulations at 29 CFR 2590.702(g) permit discrimination in favor of an individual based on a health factor.

Example: Plan grants participants who have diabetes a waiver of the plan’s annual deductible if they enroll in a disease management program that consists of attending educational classes and following their doctor’s recommendations regarding exercise and medication. This is benign discrimination because the program is offering a reward to individuals based on an adverse health factor.

TIP: The benign discrimination exception is NOT available if the plan asks diabetics to meet a standard related to a health factor (such as maintaining a certain BMI) in order to get a reward. In this case, an intervening discrimination is introduced and the plan cannot rely solely on the benign discrimination exception.

If you answered “Yes” to the previous question, STOP. There are no violations of the wellness program rules.

If you answered “No” to the previous question, the wellness program must meet the following 5 criteria.

F. Compliance Criteria

(1) Is the amount of the reward offered under the plan limited to 20% of the applicable cost of coverage? (29 CFR 2590.702(f)(2)(i))…………… Yes No

Keep in mind these considerations when analyzing the reward amount:

Who is eligible to participate in the wellness program?

If only employees are eligible to participate, the amount of the reward must not exceed 20% of the cost of employee-only coverage under the plan. If employees and any class of dependents are eligible to participate, the reward must not exceed 20% of the cost of coverage in which an employee and any dependents are enrolled.

Does the plan have more than one wellness program?

The 20% limitation on the amount of the reward applies to all of a plan’s wellness programs that require individuals to meet a standard related to a health factor.

Example: If the plan has two wellness programs with standards related to a health factor, a 20% reward for meeting a body mass index target and a 10% reward for meeting a cholesterol target, it must decrease the total reward available from 30% to 20%. However, if instead, the program offered a 10% reward for meeting a body mass index target, a 10% reward for meeting a cholesterol target, and a 10% reward for completing a health risk assessment (regardless of any individual’s specific health information), the rewards do not need to be adjusted because the 10% reward for completing the health risk assessment does not require individuals to meet a standard related to a health factor.

(2) Is the plan reasonably designed to promote health or prevent disease? (29 CFR 2590.702(f)(2)(ii)) …………………………………………………….. Yes No

The program must be reasonably designed to promote health or prevent disease. The program should have a reasonable chance of improving the health of or preventing disease in participating individuals, not be overly burdensome, not be a subterfuge for discriminating based on a health factor, and not be highly suspect in the method chosen to promote health or prevent disease.

(3) Are individuals who are eligible to participate given a chance to qualify at least once per year? (29 CFR 2590.702(f)(2)(iii)) …………………….. Yes No

(4) Is the reward available to all similarly situated individuals? Does the program offer a reasonable alternative standard? (29 CFR 2590.702(f)(2)(iv)) ……………………………. Yes No

The wellness program rules require that the reward be available to all similarly situated individuals. A component of meeting this criterion is that the program must have a reasonable alternative standard (or waiver of the otherwise applicable standard) for obtaining the reward for any individual for whom, for that period:

o It is unreasonably difficult due to a medical condition to satisfy the otherwise applicable standard; OR

o It is medically inadvisable to attempt to satisfy the otherwise applicable standard.

It is permissible for the plan or issuer to seek verification, such as a statement from the individual’s physician, that a health factor makes it unreasonably difficult or medically inadvisable for the individual to satisfy or attempt to satisfy the otherwise applicable standard.

(5) Does the plan disclose the availability of a reasonable alternative in all plan materials describing the program? (29 CFR 2590.702(f)(2)(v)) …………………………… Yes No

The plan or issuer must disclose the availability of a reasonable alternative standard in all plan materials describing the program. If plan materials merely mention that the program is available, without describing its terms, this disclosure is not required.

TIP: The disclosure does not have to say what the reasonable alternative standard is in advance. The plan can individually tailor the standard for each individual, on a case-by-case basis.

The following sample language can be used to satisfy this requirement: “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 [insert telephone number] and we will work with you to develop another way to qualify for the reward.”

If you answered “Yes” to ALL of the 5 questions on wellness program criteria, there are no violations of the HIPAA wellness program rules.

If you answered “No” to any of the 5 questions on wellness program criteria, the plan has a wellness program compliance issue. Specifically,

Violation of the general benefit discrimination rule (29 CFR 2590.702(b)(2)(i)) – If the wellness program varies benefits, including cost-sharing mechanisms (such as deductible, copayment, or coinsurance) based on whether an individual meets a standard related to a health factor and the program does not satisfy the requirements of 29 CFR 2590.702(f), the plan is impermissibly discriminating in benefits based on a health factor. The wellness program exception at 29 CFR 2590.702(b)(2)(ii) is not satisfied and the plan is in violation of 29 CFR 2590.702(b)(2)(i).

Violation of general premium discrimination rule (29 CFR 2590.702(c)(1)) – If the wellness program varies the amount of premium or contribution it requires similarly situated individuals to pay based on whether an individual meets a standard related to a health factor and the program does not satisfy the requirements of 29 CFR 2590.702(f), the plan is impermissibly discriminating in premiums based on a health factor. The wellness program exception at 29 CFR 2590.702(c)(3) is not satisfied and the plan is in violation of 29 CFR 2590.702(c)(1).

Additional compliance information regarding the other provisions in Part 7 of ERISA, including the HIPAA portability provisions and the rest of the HIPAA nondiscrimination provisions, is available on the Department’s website at: http://www.dol.gov/ebsa/pdf/CAGAppA.pdf.

Questions concerning the information contained in this Bulletin may be directed to the Office of Health Plan Standards and Compliance Assistance at 202-693-8335.