Cleveland, OH (4/3/2023) – Benefit Advisors Network (BAN) – an international network of progressive and visionary employee benefit brokers and consulting firms from across the United States and Canada – and the National Benefits Center (NBC), are spinning off from Alera Group, a top independent, national insurance and wealth services firm, to become an independent organization. Perry Braun, who previously held the role of BAN’s Executive Director, will lead the organization moving forward.
Most recently serving as Managing Director of Business Consulting at Alera Group, Braun will acquire BAN from Alera Group. Effective April 1, 2023, Braun will assume the position of President and Chief Executive Officer of BAN. He will use his extensive expertise to oversee the transition of BAN to an independently owned company.
Prior to joining Alera Group, Braun was part of the team that helped launch Alera Group in 2017. In his role as Managing Director of Business Consulting, he focused on a number of key initiatives, including working with managing partners to improve business performance contributing directly to stronger results, and partnering with the property casualty team to build a new premium finance program for Alera Group’s Property & Casualty partners.
“I’m very excited for BAN’s next chapter and even more excited to be back working with the team, members, and partners,” says Perry Braun, President and Chief Executive Officer of BAN.
“Becoming an autonomous and independent organization after five years as part of Alera Group will mutually benefit both companies and allow BAN to ramp up and re-focus on providing members with the resources they need to deliver standout services to their clients,” says Braun.
Braun continues, “As the market continues to evolve and change, so must our way of looking at our industry. The strategic actions we are taking now will provide the opportunity for a long-term sustainable company.”
BAN intentionally limits membership to the “best of the best” in their respective markets. The organizational philosophy of collaboration while providing world-class resources, such as preferred pricing arrangements and direct access to underwriters, has helped its members continue to grow. To become a member, companies have to pass a stringent screening process that includes scrutiny of the firm’s business ethics, industry knowledge, and commitment to providing the highest quality services.
About Benefit Advisors Network Founded in 2002, BAN is an exclusive, premier, international network of independent, employee benefit brokerage and consulting companies. BAN delivers industry-leading tools, technology, and expertise to U.S. and Canadian member firms so that they can deliver optimum results to their employee benefit customers. BAN intentionally limits membership because of the highly collaborative interactions. For more information, visit the company’s website at www.benefitadvisorsnetwork.com or follow them on LinkedIn.
When the Consolidated Appropriations Act, 2021 (the “CAA”) was enacted on December 27, 2020, it included a provision that prohibits group health plans and health insurance carriers from entering into certain agreements that, either directly or indirectly, restrict the release of certain information related to provider networks and de-identified encounter data, among other things. Such restrictions are commonly referred to as “gag clauses.” The CAA also requires plans and carriers to attest annually that their agreements do not include such impermissible gag clauses.
On August 20, 2021, the DOL, IRS, and HHS (the “Agencies”) jointly released an FAQ which explained that the prohibition on gag clauses was self-implementing, meaning that regulations would not be released anytime soon and that plans and carriers should use a reasonable, good faith interpretation of the statute in the meantime. The FAQ also stated that the attestation requirement would be delayed until further guidance was released.
In February 23, 2023, the Agencies released new FAQs, which provide information for completing and submitting the attestation, the first of which is due on December 31, 2023.
The following provides general information about gag clauses and completing the Gag Clause Prohibition Compliance Attestation (GCPCA).
What is a Gag Clause?
Under the CAA, a gag clause is defined as:
restrictions on the disclosure of provider-specific cost or quality of care information or data to parties such as the plan sponsor, participants, beneficiaries, or referring providers;
restrictions on electronic access to de-identified claims and encounter information or data for each participant, beneficiary, or enrollee upon request and consistent with HIPAA, GINA and ADA privacy regulations, including, on a per claim basis—
Financial information, such as the allowed amount, or any other claim-related financial obligations included in the provider contract;
Provider information, including name and clinical designation;
Service codes; or
Any other data element included in claim or encounter transactions; or
restrictions on sharing information or data described in (1) and (2), or directing that such information or data be shared, with a business associate.
The gag clause provisions of the CAA (specifically Code section 9824, ERISA section 724, and PHSA §2799A-9(a)(1)), generally prohibit plans and carriers from entering into agreements with providers, TPAs, or other service providers that include such provisions.
Where would I Typically Find a Gag Clause?
Gag clauses in this context might be found in agreements between a plan or carrier and any of the following parties:
a health care provider;
a network or association of providers;
a third-party administration (“TPA”) or pharmacy benefits manager (“PBM”); or
another service provider offering access to a network of providers.
Thus, a group health plan should confirm that its carrier, TPA and/or PBM agreements do not contain prohibited clauses. These clauses would typically be found in confidentiality or other privacy provisions of the agreements, though it is important for the agreements to be thoroughly reviewed. We would suggest working with your counsel to review the agreement to determine whether it impermissibly restricts access to specific information that would be otherwise covered under the gag clause provisions, or whether there is language that only restricts access to such information in conformity with the gag clause requirements of the CAA or other applicable state or federal law.
To which plans do the gag clause restrictions apply?
All group health plans (excluding FSAs, HRAs or other excepted benefits such as dental or vision) and insurance carriers are subject to these prohibitions. This includes self-funded and fully insured plans and grandfathered plans, as well as non-ERISA plans sponsored by non-federal governmental employers (i.e., state and local governmental employers), and church plans subject to the Internal Revenue Code.
What is the attestation requirement?
The CAA required group health plans and health insurance carriers to attest annually to the government that they have no “gag clauses” in their contracts. Plans and carriers must complete the GCPCA form electronically using the form provided by the Agencies.
When is the attestation/GCPCA form due?
The first attestation is due no later than December 31, 2023, and covers the period beginning December 27, 2020, or the effective date of the applicable group health plan or health insurance coverage (if later), through the date of attestation. Subsequent attestations, covering the period since the last preceding attestation, are due by December 31 of each year thereafter.
Who is responsible for completing the attestation for our group health plan?
That depends on whether the plan is fully insured or self-funded and your contractual arrangement with the carrier or TPA. While both the carrier and group health plan are required to submit a GCPCA with respect to a fully insured plan, a carrier may submit a GCPCA with respect to a fully insured plan that will satisfy the plan’s obligation. We expect that most carriers will agree to complete the attestation for their fully insured plans. Self-funded plans can contract with their TPA and/or their PBM to complete the attestation on behalf of the plan; however, the plan is ultimately responsible for ensuring the attestation is timely completed. It is important to communicate with your carrier or TPA before the December 31, 2023 deadline to determine who will be completing the attestation on behalf of the plan. We recommend ensuring that responsibility for completing the GCPCA is assigned well before the December 31st deadline so there are no surprises. The Agencies released an instruction manual for the webform to assist with completing the attestation, when ready for filing.
Are there penalties if our group health plan does not complete the attestation?
There are no specific penalties outlined in the CAA; however, in the FAQs, the Agencies indicate that failing to submit the attestation by the deadline may subject the plan or carrier to enforcement action. In such cases, it’s possible for the Agencies to assess a penalty of up to $100 per day per affected individual.
Where can I find more information on gag clauses and completing the attestation? The FAQs are a good place to start, as well as the HIOS GCPCA User Manual, which explains how to use the GCPCA module within the Health Insurance Oversight System (“HIOS”).
On February 21, 2023, the IRS released Final Rules amending the existing requirements related to mandatory e-filing of information returns, including Forms 1094-C and 1095-C, among others. The final rules are effective for all applicable returns due on or after January 1, 2024. While the final rule requires electronic filing for a number of different information returns, such as Forms W-2 and 1099, which were previously allowed to be paper filed by employers of a certain size, this alert addresses the changes applicable to Forms 1094 and 1095, which must be filed by applicable large employers (ALEs) as well as non-ALEs who sponsor self-funded health plans.
Under the final rules, employers filing 10 or more returns must file Forms 1094 and 1095 (and their other applicable returns) electronically. The 10-form threshold is determined based on the total number of forms the employer must file with the IRS, including Forms 1094 and 1095, as well as other information returns, such as Forms W–2 and Forms 1099, income tax returns, excise tax returns, and employment tax returns, including those that are not required to be e-filed, such as forms 940 and 941. Previously, employers who filed less than 250 of the same ACA reporting forms were allowed to choose whether to file their applicable Forms 1094 and 1095 (either the B or C forms, as applicable) by paper or electronically.
The final rules allow employers to seek a waiver in cases of undue hardship. Per the final rules, a key factor in determining whether hardship exists is whether the cost for filing the returns electronically exceeds the cost of filing the return on paper. Entities seeking a waiver must specify the type of filing to which the waiver applies, the period to which it applies, and the entity must follow any applicable procedures, publications, forms, instructions, or other guidance, including postings to the IRS.gov website, when requesting the waiver. Further, the final rules allow the IRS to grant exemptions from the requirements in certain instances.
Conclusion
All ALEs and many non-ALEs (who report due to sponsoring a self-funded health plan) will be impacted by these changes and will be required to file their tax year 2023 Forms 1094 and 1095 electronically unless they seek and are granted a hardship exception by the IRS. Impacted entities should take the time between now and next year to engage a filing vendor that can assist them with their electronic filing obligations.
On January 30, 2023, President Biden issued a Statement of Administration Policy announcing his intent to extend the COVID-19 national and public health emergencies (collectively, “COVID-19 Emergencies”) set to expire on March 1 and April 11, respectively, until May 11, 2023. While the COVID-19 Emergencies have not officially been extended at this time, if they are extended through May 11, 2023, then they will end on that date.
This announcement comes more than 3 months prior to the anticipated end of the COVID-19 Emergencies and is intended to ensure that states, group health plans, health insurers, health care providers, and health plan participants, among many others, have sufficient advance notice, as the end of the COVID-19 Emergencies may trigger significant changes for health plans and employee benefits which are described in more detail below.
Employee Benefits Provisions Tied to COVID-19 Public Health Emergency
COVID-19 Testing
The Families First Coronavirus Response Act, which was enacted on March 18, 2020, requires group health plans (self-funded, fully insured, grandfathered, and non-grandfathered plans, but not excepted benefits such as dental or vision) and health insurance issuers to cover testing or certain other items or services intended to diagnose COVID-19 without cost-sharing (deductibles, copays, or coinsurance), prior authorization, or other medical management requirements. It also permits federal agencies to implement the FFCRA through sub-regulatory guidance, program instruction, or otherwise. The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), which was enacted on March 27, 2020, expanded the FFCRA to, among other things, include a broader range of reimbursable COVID-19 diagnostic items and services that must be covered without cost-sharing, prior authorization, or medical management during the public health emergency, including testing provided by out-of-network (OON) providers.
As the COVID-19 pandemic progressed and the FDA authorized at-home OTC COVID-19 diagnostic tests that individuals could self-administer and self-read to diagnose COVID-19, on January 10, 2022, the agencies released initial guidance for plans and carriers, which required them to cover FDA approved at-home, OTC COVID-19 tests (up to 8 total per individual per month) without cost sharing, prior authorization, or medical management, and without the need for a prescription or recommendation of a health care provider during the pendency of the COVID-19 public health emergency. Additional FAQs clarifying some of the initial guidance were released on February 4, 2022.
COVID-19 Vaccines
Additionally, the CARES Act requires the COVID-19 vaccine to be provided cost-free (similar to other preventive care vaccines) by any non-grandfathered group health plan pursuant to the ACA’s preventive care rules, regardless of whether the vaccine is administered by an OON or in-network (INN) provider.
Employee Benefits Provisions Tied to COVID-19 National Emergency
Group Health Plan Notification, Premium, and Claims Filing Deadlines Applicable to Participants
On April 28, 2020, in an effort to assist employees in meeting their various notice, election, and claims filing deadlines that were severely disrupted as the nation was in shutdown, federal agencies (the DOL, HHS, and IRS) released the Extension of Certain Timeframes for Employee Benefit Plans, Participants, and Beneficiaries Affected by the COVID-19 Outbreak Final Rule (“Covid-19 Extension Final Rule”) which provided participants, enrollees, and members with relief from the below applicable deadlines from March 1, 2020 until 60 days after the end of the COVID-19 national emergency:
The 30-day period (or 60-day period, if applicable) to request a special enrollment;
The 60-day election period for COBRA continuation coverage;
The deadline for making COBRA premium payments;
The deadline for individuals to notify the plan of a qualifying event or determination of disability;
The deadline within which employees can file a benefits claim, or a claimant can appeal an adverse benefit determination, under a group health plan’s or disability plan’s claims procedures;
The deadline for claimants to file a request for an external review after receipt of an adverse benefit determination or final internal adverse benefit determination; and
The deadline for a claimant to file information to perfect a request for external review upon finding that the request was not complete.
The above relief was further extended in EBSA Disaster Relief Notice 2021-01, which extended the above deadlines until the earlier of: (a) one (1) year from the date (on or after March 1, 2020) that an individual is first eligible for relief; or (b) 60 days after the end of the COVID-19 national emergency.
Group Health Plan Notice and Disclosure Requirements Applicable to Plan Sponsors
Relief was not only provided to employees. The COVID-19 Extension Final Rule and EBSA Disaster Relief Notice 2021-01, provided group health plans with relief from providing COBRA election notices for qualifying events occurring from the earlier of (a) one (1) year from the date (on or after March 1, 2020) that the group health plan was eligible for relief; or (b) 60 days after the end of the COVID-19 national emergency.
Group health plans and plan sponsors were also afforded relief due to COVID-19 disruptions in EBSA Disaster Relief Notice 2020-01, which eased the burden for group health plans, disability plans, and pension plans to provide notices and disclosures required under ERISA and Internal Revenue Code of 1986 (the “Code”) by providing good faith relief for plans or employers who fail to timely furnish a notice, disclosure, or document if they make any required notice or disclosure as soon as administratively practicable under the circumstances from the period of March 1, 2020, through 60 days after the announced end of the COVID-19 National Emergency.
Additionally, pursuant to EBSA Disaster Relief Notice 2020-01, group health plans were provided relief from certain ERISA electronic disclosure requirements for plan participants and beneficiaries who they reasonably believed had effective access to electronic means of communication, including email, text messages, and continuous access websites.
Impact of the End of the COVID-19 Public Health and National Emergencies
If the COVID-19 Emergencies end as of the date indicated in the Statement of Administration Policy, then all of the above-referenced relief will expire as follows:
The provisions of the FFCRA and CARES Act which require COVID-19 diagnostic tests to be provided without cost-sharing (deductibles, copays, or coinsurance), prior authorization, or other medical management requirements are tied to the COVID-19 public health emergency and, therefore, will expire on May 11, 2023, when the public health emergency ends. Accordingly, group health plans and insurers will no longer be required to cover COVID-19 at-home or in-person diagnostic tests without cost sharing. Any plan materials, such as SPDs, describing coverage for COVID-19 testing by the plan should be amended as necessary.
Provisions governing coverage of the COVID-19 vaccine are also tied to the COVID-19 public health emergency. Therefore, after May 11, 2023, administration of the COVID-19 vaccine will still be covered without cost (similar to other preventive care vaccines) by health plans and insurers; however, plans and insurers will not be required to cover vaccines administered by OON providers. Any plan materials, such as SPDs, describing coverage for COVID-19 vaccines by the plan should be amended as necessary.
The COVID-19 Extension Final Rule and EBSA Disaster Relief Notice 2021-01 are tied to the COVID-19 national emergency declaration and will expire on July 10, 2023 (which is 60 days after the end of the COVID-19 national emergency). Thus, all extensions under the COVID-19 Extension Final Rule that are still effective for any plans or participants (i.e., those that are still in the 1-year extension window) will expire and the applicable clock will begin ticking. For example, if an individual received their COBRA election notice on October 1, 2022, the time from October 1, 2022, through July 10, 2023, is disregarded due to the COVID-19 Extension Final Rule. After the outbreak period ends on July 10, 2023, the individual would have until 60 days after July 10, 2023, to elect COBRA, or September 8, 2023. Therefore, it is imperative that employers use the time between now and May 11 to inform participants and beneficiaries of these upcoming changes so they understand how their rights will be impacted. Any plan materials, such as SPDs, notices, or other communications describing these extensions should be amended accordingly.
Finally, EBSA Disaster Relief Notice 2020-01 is also tied to the COVID-19 national emergency. Accordingly, after July 10, 2023, employers will no longer have relief from timely providing required notices to participants, and any employers who used the relief as a basis to justify electronic delivery of ERISA plan materials will need to ensure they comply with ERISA electronic delivery requirements for plan materials.
Conclusion
While employers do not need to do anything at this time, particularly as the COVID-19 Emergencies’ end date has not been officially announced, the Statement of Administration Policy indicates that the COVID-19 Emergencies will likely be coming to an end in the next several months. Therefore, employers who sponsor group health plans are encouraged to work with their carriers, TPAs, COBRA administrators, and other vendors to develop strategies for ensuring proper communication of the end of the COVID-19 Emergencies and the impact on participants and their benefits. Further, they should identify SPDs and other plan materials that may need to be amended. Additionally, any employers subject to ERISA who relied upon the relaxed electronic delivery standards set forth in Notice 2020-01 and 2021-01 should ensure they review their workforce and strategies to ensure compliance with electronic delivery requirements after July 10, 2023 (unless a different COVID-19 national emergency end date is otherwise announced).
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About the Authors. This alert was prepared by Barrow Weatherhead Lent LLP, a national law firm with recognized experts on the Affordable Care Act. Contact Stacy Barrow or Nicole Quinn-Gato at sbarrow@marbarlaw.com or nquinngato@marbarlaw.com.
This email is a service to our clients and friends. It is designed only to give general information on the developments actually covered. It is not intended to be a comprehensive summary of recent developments in the law, treat exhaustively the subjects covered, provide legal advice, or render a legal opinion.
Benefit Advisors Network and its members are not attorneys and are not responsible for any legal advice. To fully understand how this or any legal or compliance information affects your unique situation, you should check with a qualified attorney.
Originally published by WorldatWork on January 12, 2023
It’s a new year, and for many of us, that means a list of resolutions to traverse. Look at any list and you can find goals like exercising more, learning a new skill or hobby, or saving more money. They all share a similar trait: taking care of oneself.
As we reviewed the past several years, we saw well-being trends in the workplace that signaled the need for more self-care (some brought on by the COVID-19 pandemic). In 2021, it was the Great Resignation. In 2022, it was quiet quitting. Due to stress and burnout, workers were either walking away entirely or putting up boundaries when it came to their job.
In 2023, well-being will no doubt continue to be top of mind for every employer, so we asked several HR practitioners and experts to share their thoughts on what they saw worked in 2022 and what they anticipate seeing in this space in the near future.
Reflecting on 2022
According to Gallagher’s 2022 Benefit Strategy and Benchmarking SurveyOpen in a new tab, for 79% of employers, emotional well-being emerged as the dimension of well-being that has become more important since 2020, driving new solutions in virtual or telephonic mental health counseling, stress management programs, time off for mental health and mental health training for managers.
“Employees come to work as ‘whole people,’ and whatever is going on with them physically, emotionally, financially, and importantly — at work — will have a significant impact on overall health and well-being, including healthcare costs, retention, and engagement,” said Kathleen Schulz, global innovation leader for organizational well-being at Gallagher.
“The U.S. Surgeon General’s warningOpen in a new tab brought additional visibility to the impact on toxic workplaces, and how they negatively impact both physical and mental health. The culture within an organization will influence employee behavior, employee behavior will impact risk and, ultimately, outcomes related to the business, their people, and the customers they are serving,” she continued. “It’s all connected.”
Bobbi Kloss, director of human capital management services at Benefit Advisors Network, agreed that emotional well-being was at the forefront for employers and employees in 2022.
“Today, the state of the nation in terms of fear, frustration, anger, isolation, loss of family and friends stemming from COVID, racial injustices, and political unrest, employers are realizing the urgent need for mental health solutions for their employees,” she said.
Kloss also said employers are seeking ways to transform their culture to show that employees are their greatest asset.
“Employers are once again turning to full-service Employee Assistance Programs (EAPs), and supervisors are learning to inquire about an employee’s current circumstances when performance deteriorates, instead of automatically writing up that individual,” she said.
By emphasizing teamwork, open door policies, and using programs such as DiSCOpen in a new tab for communication tools, policies are changing to show that the company and its employees are working together as an integral team to drive forward the company mission, Kloss added.
“With a multigenerational and increasingly diverse workforce, employee needs and expectations are changing,” she said. “Voluntary benefits allow employers to satisfy a wider variety of interests while avoiding additional costs and administrative requirements. Employees win as employers build a benefits package that aligns more closely with their employees’ needs, often at pre-tax dollars or discounted group rates.”
Allison Salkeld, director of global well-being at Delta Air Lines, saw a focus on resiliency, emotional well-being tools and resource and family care options to better support working parents returning to the office full-time.
“There was also a big focus on equipping leaders to support the well-being needs of their employees while also caring for themselves,” she said. “And more thought into financial well-being tools and resources, and coaching and general awareness of social determinants of health.”
According to a SoFi at Work studyOpen in a new tab, 38% of employees said financial stress negatively impacts their mental health, 23% said it affects their ability to focus and 18% said it hurts productivity.
Record-high inflation rates and economic concerns have since compounded the issue, said Barrett Scruggs, SoFi at Work’s vice president of financial well-being.
“Now, 84%Open in a new tab of employees believe their employers should be responsible for their financial well-being — and companies are listening,” he said. “As a result, businesses are acknowledging the shift in their employees’ financial situations and implementing new employer contribution plans beyond traditional 401(k) matching to directly support their short-term financial needs.”
Since the CARES Act passed in 2020, allowing employers to offer up to $5,250 of student loan repayment benefits annually through 2025, companies have taken a more prominent role in addressing employees’ student debt, Scruggs said.
And student loan contribution plansOpen in a new tab have grown increasingly popular, he said, as they allow employees to set aside a percentage of their paycheck toward student loan repayment with a match from their employer, similar to retirement contributions.
In October, the U.S. Surgeon General released his newest Framework for Mental Health & Well-Being in the WorkplaceOpen in a new tab report highlighting five essentials for workers in organizations and businesses to help leaders develop policies and practices that support the mental health and well-being of workers.
They include:
protection from harm (creating the conditions for physical and psychological safety is a critical foundation for ensuring mental health and well-being in the workplace)
connection and community (fostering positive social interaction and relationships in the workplace supports worker well-being)
work-life harmony (professional and personal roles can create work and non-work conflicts)
mattering at work (people want to know that they matter to those around them and that their work matters)
opportunities for growth (when organizations create more opportunities for workers to accomplish goals based on their skills and growth, workers become more optimistic about their abilities and more enthusiastic about contributing to the organization).
Areas of Success
As employers develop their well-being strategies, the most productive ones are those that focus on the total well-being of employees, Kloss said.
“We never know what each person’s individual needs are, and employers have had a tendency to assume they know what their employees need without asking,” she said. “Now they are asking and recognizing that we all have different well-being needs at different stages of our lives. Being more intentional in meeting the holistic needs of their workforce has been a positive outcome.”
Salkeld saw more emphasis on resiliency tools and basic training on emotional well-being support for leaders. There was also more education on topics such as nutrition, resources and flexibility to fight fatigue, equitable access to healthy foods and physical activity.
“We are thinking beyond that though,” she said. “The other part is thinking about how well-being can be infused into your culture and people strategy, and how you think about the composition of roles, team dynamics and physical space where people work and refine so that each maximize the employee’s well-being and the company’s commitment to that.”
Concerning financial well-being, Scruggs saw an increase in employers offering education resources and tools to help employees get on track. For example, providing access to financial planning support or budgeting tools can be one of the most effective yet budget-friendly ways to offer support. These resources empower employees to take control of their financial well-being, especially when larger monthly payments like student loans and mortgages come into play.
Additionally, because each employee has unique financial needs, offering well-being benefits for employees at various life stages can increase job satisfaction, engagement and morale across a diverse workforce, he said.
“Employees have different financial goals, whether paying back student loan debt, building their emergency savings fund or preparing for retirement. HR leaders who create personalized, flexible well-being programs demonstrate they’re listening to their employees’ needs and have more success as a result.”
Room for Improvement
In 2022, 23.8% of respondents to Gallagher’s National Strategy and Benchmarking SurveyOpen in a new tab currently didn’t have a strategy for well-being (although they may have had some well-being resources in place). This was up over 3% from 2021, and only 24.7% had a comprehensive “whole person” approach that encompassed physical, emotional, financial and career well-being aspects, down slightly from 2021.
“Well-being can’t be thought of as a program,” Schulz said. “It needs to be a business and cultural imperative and modeled by leaders as they are influencing the behavior of everyone around them.
“Employee emotional well-being is an area that needs improvement as well. While progress has been made enhancing resources and reducing the stigma surrounding mental health, access to providers and treatment remains an issue.”
Scruggs shared that 83%Open in a new tab of employees were motivated to improve their financial well-being, but only 53% said they knew how to get started.
“Offering new benefits is only the first step,” he said. “To help drive employee engagement, HR leaders must also ensure resources are accessible, customizable and interactive. HR and benefits teams must also effectively and frequently communicate the benefits to ensure adoption.
“While financial literacy and student loan debt have been a big part of financial benefits conversations in the last few years, college planning is one area that has historically been overlooked. In the last 20 years, the cost of attending college with in-state tuition at public national universities has increased by nearly 75%Open in a new tab,” he said. “As a result, employers should consider offering a 529 college savings program that allows employees to save for education costs while also taking advantage of tax benefits.”
Delta Air Lines’ Salkeld added that defining workplace flexibility was also a need.
“Most people assume that it’s remote work arrangements, which is part of it, but the other part is actually thinking about why employees like remote work,” she said. “It boils down to flexibility, empowerment and choice in how they show up — what clothes they wear, where they take meetings, preparing their own meals and being able to care for themselves seamlessly as they complete their work.”
What to Watch for in 2023
As employers plan, there are several short-term and long-term well-being strategies they should invest in.
Kloss encouraged employers to consider emotional well-being programs, EAPs and training supervisors to manage and bring empathy to their staff. Furthermore, employers should consider programs where employees can turn their PTO into other benefits, such as on-demand wage payment solutions; social-employee engagement solutions, where not only supervisors are rewarding employees, but co-workers also encourage teams, have become beneficial; and health plan care coordinators who can tailor programs to individual employee needs as well as educate on benefit plans and available resources.
In 2023, Scruggs said employers should focus on long-term financial health benefits to help offset inflation, such as pay raises, 401(k) matching, HSA contributions and tuition reimbursement.
“We found that the top five financial benefitsOpen in a new tab employees want their company to add, improve or expand are emergency savings fund (64%), retirement matching/401(k) (64%), financial planning tools (62%), budget planning tools (61%) and homeownership assistance (60%),” he reported.
Scruggs also suggested employers monitor the federal student loan payment moratorium in 2023 closely and consistently communicate policy changes and their impacts to employees.
“Investing in educational resources such as student loan debt counseling in advance of payments resuming will also help ensure that employees’ short-term and long-term needs aren’t negatively impacted,” he said.
And as DE&I continues to be a major priority for companies, employers should consider equitable and inclusive well-being benefits that cover a diverse set of employees.
“Emergency savings funds are a great example of a benefit that helps employees at all income levels and life stages,” Scruggs said. “Everyone will face a costly emergency at some point, from a leaky roof to an unexpected medical bill. Offering an emergency savings program can help employees with their short-term needs.”
Evaluating What Works
Data and analytics will be the core tenets of any successful total rewards program in 2023, Salkeld said.
The view of effectiveness and ROI will also look very different than it would for a compensation program, she explained. When developing an incentive plan, you have a formula that tells you where you precisely come in above or below target performance goals and can allocate money accordingly. As a result, it’s a more nuanced approach to thinking about targeted performance and outcomes for this area.
“Companies will need to think about that balance in understanding economics, what employees truly want and need, what conditions they need to manage at the population level, and then think differently about measurements of success in this space,” Salkeld said. “It is a mix of health outcomes, and employee engagement, retention and satisfaction.
Overall, well-being is a broad category, and its meaning can be subjective, Gallagher’s Schulz said.
“Organizations need to identify what does organizational well-being means to them, what types of well-being initiatives will be most meaningful to their employees and what are the metrics that indicate progress,” she said.
In the short term, that means employers need to have a strategy in place for collecting the employee voice.
“It’s the only way to ensure an organization’s strategy and budget are focused on the areas that are most important and relevant to their employees,” Schulz said.
Longer term, Schulz said building connectivity between often siloed strategies will increase effectiveness and value to employees.
“Investing in financial well-being programs like coaching and student loan repayment can help reduce stress,” she said. “Evaluating and expanding absence management and leave programs can ensure compliance in an increasingly complex regulatory environment and also provide important time off for employees to recharge in a way that meets their unique needs.”
“Investing in a comprehensive communications strategy that helps connect the hearts and minds of employees, while increasing awareness of total rewards resources,” she said, “will help employers manage and optimize benefit costs and enhance their competitiveness in this continuously challenging labor market.”
Editor’s Note: Additional Content
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