Do Wellness Programs Protect – or Take Advantage – of Your Data?

Screen-Shot-2014-09-22-at-9.08.49-PM-e1411434567513This post from Cathy Kenworthy, Interactive Health CEO, was originally published in LinkedIn here. Please visit the original piece to leave any comment.

A series of stories in the media over the past few days, triggered by the Wall Street Journal, have raised alarms about how employers and third parties might use data associated with worksite wellness and health management programs.  While none of these stories relates directly to our work at Interactive Health, they can be scary.  We should set the record straight:  wellness programs work wonders to combat the national epidemic associated with heart disease, diabetes, obesity and many other health risks – but only if they are done well.  And, “done well” in my view means that the privacy of participants is scrupulously protected.

These days, data privacy issues abound.  Whether it is Tim Cook fending off the FBI’s demand for a “back door” to the iPhone, the relentless pace of breaches to financial information, or the adventures of Julian Assange and WikiLeaks, we are in unprecedented terrain when it comes to what we can all know about one another.  Health data, however, is perhaps the most personal information each of us has.  The concerns that individual employees have about privacy of their health data are real and fair.

HIPAA – known as the Health Insurance Portability and Accountability Act – plays a vital role.  This act requires that all parties with access to “personally identifiable health information” are obligated to protect that information.  Some of the media coverage has created questions about the degree to which HIPAA serves this role.

However, for those of us who work in the wellness field, there is no ambiguity.  Compliance with HIPAA is essential.  No games allowed.  HIPAA ensures that our work has the opportunity to be enduring and our efforts with individuals can be based on trust.

How can you know whether your firm is working with a vendor that believes this?  Look no further than whether that firm has chosen to have its data management practices credentialized and audited by a third party.  At Interactive Health, we are proud of our long-standing accreditation through the National Committee for Quality Assurance (NCQA).  The NCQA rigorously audits how we manage data, as do many of our large clients – including clients in the defense industry, banks, and other industries accustomed to significant scrutiny.  And data shared with an employer is not just aggregated – rather it is depersonalized, meaning even inferences are not possible.  If the employee population or a particular location is too small to prevent those inferences, we simply do not provide data, even aggregated data.

I must say I am incredulous, and highly concerned, that certain health management firms find it relevant to try and predict how many females in a given employee population are trying to get pregnant.  The health crisis in the US is driven by many lifestyle choices that need urgent attention – and a woman’s desire to start a family is most definitely not one of those.  At Interactive Health, we find in our data that emotional health risk, such as anxiety and stress, is highest among women in their 20s, compared to any other gender and age demographic.  Wellbeing is certainly not fostered among this population by an intrusive and tone-deaf application of health analytics among firms that appear not to understand their obligations under HIPAA.

The best wellness programs are data-driven, focus on an employee’s total health, connect participants to care and tie into all elements of an employer’s benefit program.   These programs use good judgment.

In these programs, wellness companies use data in partnership with employees who willingly participate in tests. As a result, they receive coaching and ongoing engagement to help them reach the goals we set with them. The business case for this is solid, too – employers use the aggregate (and, as described above, de-personalized) data from their program to design smarter and more affordable health benefit packages.

Well-designed programs do tremendous good by lowering health care spending for both employers and employees, while also positively impacting many other areas, including job satisfaction, recruitment success and retention of workers.

The good that is done by effective wellness programs is important.  In fact, these programs might be the signature achievement of this generation of business management.  I hope that 20 years from now we will marvel at the reduction in heart disease and diabetes with the same admiration that many of us look at the reduction in tobacco use over the last 20 years.

A mission this important requires all players to embrace complete and full efforts to protect the privacy of all participants.