Guidelines for Reasonable Alternatives
A. Your Plan for Health
Your Plan for Health (“YP4H”) is a wellness incentive program offered by The Ohio State University to benefit eligible employees and their spouses enrolled in an Ohio State medical plan. YP4H is powered by Virgin Pulse (“VP”) and managed by the university’s Office of Human Resources (“OHR”). Eligible employees and their spouses who choose to participate in YP4H (“Members”) may earn various financial incentives, including a monthly medical premium credit, contributions to a health reimbursement arrangement account, and amounts that can be spent to purchase goods through VP’s shopping portal (known as PulseCash). Members obtain these incentives by accruing points. Points can be earned in a number of ways, including by (i) completing an annual Personal Health and Well-being Assessment, (ii) submitting verified biometric health data, (iii) obtaining certain biometric health values, (iv) tracking physical activity, (v) receiving health coaching, and (v) participating in various challenges, healthy habits, and educational opportunities.
B. Laws Requiring Reasonable Alternative Standard
Under federal law, employer-provided wellness programs that offer incentives for achieving ‘health-contingent’ standards (i.e., obtaining certain health outcomes or performing physical activity) must provide a ‘reasonable alternative’ standard that is not health-contingent. The reasonable alternative standard will allow a participant whose health makes it unreasonably difficult, or medically inadvisable to attempt, to achieve the health-contingent standard to obtain the incentive. As a result, every individual participating in the program should be able to receive the full incentive, regardless of any health factor.
II. Guidelines for Reasonable Alternatives
This document provides guidelines for the university, including OHR, with respect to reasonable alternative standards available under YP4H.
A. Availability of Reasonable Alternatives
OHR will work in coordination with VP to ensure that every Member is able to receive the full incentive, regardless of any health factor, by providing Reasonable Alternatives (RA) to earn YP4H points. With an RA, a Member can earn points by achieving standards that are not health-contingent. RAs are available to Members whose health makes it unreasonably difficult to achieve a health-contingent standard, or medically inadvisable to attempt to achieve such a standard (a “Health-Based Limitation”). Depending upon the Member’s circumstance, an RA may replace physical activity tracking on a short-term basis (a “Short-Term RA”) or a long-term basis (a “Long-Term RA”), or may operate to waive the requirement to obtain certain biometric health values (a “Biometric Values Waiver”).
B. Notice of Reasonable Alternative
OHR and VP will provide every Member with notice of the availability of RAs under the YP4H program, including information on how to request an RA.
C. Eligibility for a Reasonable Alternative
Generally, a Member may be eligible for an RA if they have a Health-Based Limitation. Depending on the nature of the Member’s Health-Based Limitation, they may be eligible for a Short-Term RA, a Long-Term RA, or a Biometric Values Waiver.
1. Short-Term RA
A Short-Term RA is available when a Health-Based Limitation is expected to persist for 90 days or less. For purposes of a Short-Term RA, a Member is required to certify that he or she suffers from a Health-Based Limitation and provide a good-faith estimate of the Health-Based Limitation’s duration. The Short-Term RA will be applied to the Member’s account for the period of time that the Health-Based Limitation is expected to last.
2. Long-Term RA
A Long-Term RA is available when a Health-Based Limitation is expected to persist for more than 90 days. A Long-Term RA requires verification by a Member’s physician. The Long-Term RA will be applied to the Member’s account indefinitely.
3. Biometric Values Waiver
A Biometric Values Waiver is available when a Health-Based Limitation prevents a Member from obtaining certain biometric health value goals incentivized with YP4H points (e.g., total cholesterol less than 200, blood pressure less than 140/90, etc.). A Biometric Values Waiver requires verification by a Member’s physician.
D. Requesting a Reasonable Alternative
VP administers the YP4H RAs. VP is responsible for (i) fielding and responding to Member inquiries pertaining to RAs and Member requests for an RA (ii) making the determination as to whether the Member satisfies the conditions to obtain an RA, and (iii) implementing the appropriate RA on that Member’s account.
A Member may contact VP to request an RA. Based on discussion with the Member, VP will provide the appropriate RA request form(s) for a Short-Term RA, Long-Term RA, or Biometric Values Waiver.
OHR will implement procedures designed to ensure that all Member inquiries directed to OHR or to the OSU Health Plan customer service departments that pertain to RAs are properly directed to VP.
E. Using a Reasonable Alternative
If approved for an RA, a Member may continue to earn points towards incentive levels under the YP4H program while experiencing a Health-Related Limitation by satisfying non-health-contingent standards.
If approved, a Short-Term RA will be applied to the Member’s account effective as of the latest of the following: (i) the first day of the Health-Related Limitation (as indicated on the RA request form); (ii) the day that is 14 days prior to the date of the RA request; or (iii) the first day of the then-current program. The Short-Term RA will terminate as of the end-date indicated on the Member’s request form.
If approved, a Long-Term RA will be applied to the Member’s account effective as of the latest of the following: (i) the first day of the Health-Related Limitation (as indicated on the request form); (ii) the day that is 14 days prior to the date of the RA request; or (iii) the first day of the then-current program. The Long-Term RA will continue indefinitely.
3. Biometric Values Waiver
If approved, a Biometric Values Waiver will be applied to the Member’s account for the then-current program term. No more than one Biometric Values Waiver will apply per Member per calendar year.
Updated August 2019