Participatory Wellness Programs
A participatory wellness program rewards employees for taking part, such as attending a seminar or completing a health risk assessment, without requiring any health result. These are the simplest programs to run.
What to know.
Under the federal health plan nondiscrimination rules, a participatory program generally has to be open to all similarly situated individuals and has no reward limit. Other laws, including the ADA, still apply to any medical questions.
Keep medical information separate from personnel files, give employees notice of the program and make sure taking part is voluntary.
Where to look next.
Wellness Rewards Overview
How the account works.
Wellness Programs and the ADA
Voluntary participation and incentives.
Wellbeing and Population Health
Programs that support employees.
What Makes a Program Participatory.
A participatory program rewards participation, not results. Attending a seminar, completing a health risk assessment or joining a walking challenge are common examples. Because no health outcome is required, these programs face fewer rules than health-contingent programs.
Even so, other laws can apply, including privacy rules for health information and nondiscrimination rules. The way questions are asked and who sees the answers both matter.
Keep the program simple and voluntary, tell employees what is collected and who sees it, and limit access to information.
Common questions on this topic.
Four questions to settle before you rely on it.
Is there a limit on the reward?
Under the health plan wellness rules, not for a participatory program. Other laws may apply.
Can we ask health questions?
Yes with care. The ADA requires that participation be voluntary.
Who sees the results?
Keep results with the vendor and limit what the employer sees to participation. Ask the vendor how data is protected.
Are cash rewards taxable?
Yes. Cash and cash equivalents are taxable wages.
Can we offer a reward?
Often yes. Participatory programs are generally easier to reward, but the type of reward affects taxes.
Do small employers have different rules?
Many rules apply regardless of size. Ask your adviser.
What records should we keep?
The program description, notices to employees and a record of who participated.
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General information, not legal or tax advice. Plan-specific questions belong with your counsel or CPA, and we will bring them in.
Related guides.
Wellness Rewards Account
The overview this page belongs to.
Compliance Services
How CFH supports the compliance side of your plans.
Health-Contingent Wellness Programs
A related question on the same program.
Where the Rules Come From.
The laws and rules named on this page link to the statute or regulation they come from. This is general information, not legal or tax advice, and rules change, so check the current text.
Wellness Program Rules (29 CFR 2590.702)
The health plan nondiscrimination rules for wellness programs.
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