For individuals, the proposed rules require that the wellness programs and their incentives be laid out simply so that participants can understand them, and that protections and appeals processes are in place for individuals who have legitimate reasons for failing to meet specific metrics.
"They have to accommodate the consumers who can't meet the standards," Reed says.
Brenda L. Rooney, medical director for Community and Preventive Care Services at Gundersen Lutheran Health in La Crosse, WI, says the federal government was smart to require no baseline incentives for wellness programs and to impose a reasonable ceiling for those incentives.
"Incentives are good but they are not the be-all and end-all. Incentives can backfire on you as well," she says. "That there is a limit is probably good. People start to expect incentives and then they tend to use the incentives to reward a behavior change. Pretty soon, if you to pull the incentive away, will the behavior change go back to the beginning?"