Wellness Plan Success: Essentials of Compliance and Engagement

Copyright 2017 – Not to be reproduced without express permission of Benefit Express Services, LLC 1

Wellness Plan Success: Essentials of Compliance and Engagement

Larry Grudzien

Attorney at Law

Lawrence (Larry) Grudzien, JD, LLM is an attorney practicing exclusively in the field

of employee benefits. He has experience in dealing with qualified plans, health and

welfare, fringe benefits and executive compensation areas. He has more than 35

years’ experience in employee benefit law.

Mr. Grudzien was also an adjunct faculty member of John Marshall Law School’s

LL.M. program in Employee Benefits and at the Valparaiso University’s School of

Law. Mr. Grudzien has a B.A. degree in history and political science from Indiana

University, J.D. degree from Valparaiso University School of Law and LL.M. degree

in tax from Boston University School of Law. He is a member of Indiana and Illinois

Bars.

About Larry

3

Larry Grudzien

ERISA Attorney

Copyright 2017 – Not to be reproduced without express permission of Benefit Express Services, LLC

• Review requirements under HIPAA

• Review requirements under the Internal Revenue Code

• Review requirements under ERISA

• Review requirements under GINA

• Review requirements under ADA

• ACA

• Questions

Agenda

4Copyright 2017 – Not to be reproduced without express permission of Benefit Express Services, LLC

Wellness Program Requirements Under HIPAA


• Group health plans and insurers cannot discriminate against participants on the basis of any health

factors.

• Discrimination encompasses:

Eligibility:

• Enrollment, effective date, waiting periods, benefits

Premiums or contributions:

• Including discounts, rebates or differential mechanisms

• But wellness plans are an exception

• Violations of HIPAA nondiscrimination rules can result in:

Code-based excise taxes of $100 per day per person per failure.

DOL audit and civil action to enforce rules.

Private right of action under ERISA §502 to enforce rules

Fundamental Principles


• Guidance is provided in the final regulations for evaluating the permissibility of wellness

programs under HIPAA’s nondiscrimination requirements.

• Separate requirements apply under HIPAA depending upon whether the wellness program is:

a health-contingent program (it provides a reward that is contingent on satisfaction of a health-

contingent standard related to a health factor)

a participation-only program (it simply rewards participation in the program regardless of whether the

individual satisfies a health-contingent standard related to a health factor).

• In a nutshell, if the program is health-contingent-based, the final regulations require the program

to meet five specific conditions.

• If the program is participation-only, the final regulations require only that the program be

available to all similarly situated individuals.

Wellness Programs in General


• A wellness program can take many forms (and might not even be called a wellness program), but its

defining feature is usually a reward to encourage healthier lifestyles—reduced premiums or co-pays in

exchange for quitting smoking or reducing bad cholesterol levels, for example.

• Employers and insurers hope that by encouraging healthier lifestyles, health care costs can be contained

or reduced.

• HHS has recommended that employers “consider providing health promotion or wellness programs and

disease management programs for employees as part of their health benefits.”

• Some wellness programs simply make their services available to those who wish to use them, but others

target individuals who have specific medical conditions, such as asthma or diabetes, and make special

help available to them.

• For example, the program may provide case managers who will help monitor compliance with medication

protocols and schedule appointments with physicians or therapists; special educational opportunities;

newsletters; and discounts on co-pays for required medications.

What is a Wellness Program?


The rewards offered by wellness programs can vary greatly, from T-shirts or

water bottles to significant reductions in premiums, co-pays, or deductibles.

In addition, the health-contingents necessary to qualify for the reward can vary

greatly, from actually quitting smoking or lowering cholesterol to merely attending

a smoking-cessation class or signing a certification that weekly exercise sessions

have been completed.

What is a Wellness Program?


• HRAs are often used by wellness programs to identify the individuals who can benefit

the most from the wellness programs and who represent the greatest opportunities for

cost containment.

• In addition, health risk assessments can be used by plan participants and beneficiaries

to identify areas of possible concern and to set health-related goals.

• HRAs can also be much more hands-on and can range from basic screenings at the

employee’s worksite (e.g., blood pressure, cholesterol, body mass index, blood sugar,

and bone density) to complete physical examinations at a doctor’s office or a hospital.

• Often the initial HRA is used as a baseline against which subsequent assessments are

measured to track progress toward health-related goals.

• An employer cannot make taking HRAs mandatory to receive coverage.

Health Risk Assessments (HRAs)


Wellness programs that do not condition eligibility for a reward upon a participant’s ability

to meet a health Health-Contingent are permissible if participation in the programs is

available to all similarly situated individuals.

Examples of participation-only programs include:

• incentives to participate in a health fair or testing (regardless of outcome)

• waiver of co-payment/deductible for well-baby visits

• reimbursement of health club membership

• reimbursements for smoking cessation programs (regardless of outcome)

• a program that rewards employees who complete a health risk assessment, without

further action related to health issues identified as part of the health risk assessment

Participation-Only Programs


• Health-contingent wellness programs require individuals to satisfy a health-contingent standard related to

a health factor as a condition for obtaining a reward.

• A “reward” includes both an incentive in the form of a reward (e.g., premium discount, waiver of cost

sharing amount, an additional benefit or any financial or other incentive) and an incentive in the form of

avoiding a penalty (e.g., the absence of a premium surcharge or other financial or nonfinancial

disincentive).

• Health-contingent programs are further divided into activity-only programs and outcome-based programs:

Activity-only programs require individuals to complete an activity related to a health factor to obtain the reward, but

the activity need not result in a specific health outcome.

• For example, the employer may provide a reward for a walking, diet, or exercise program.

Outcome-based programs require individuals to attain or maintain a specific health outcome in order to obtain the

reward.

• For example, an employer could provide a reward for not smoking, for obtaining a certain result on a

biometric screening, or for maintaining a certain body mass index (BMI).

Health-Contingent-Based Programs


Each health-contingent program must meet five requirements to be exempt from HIPAA

nondiscrimination provisions.

• The Reward Must Be No More Than 30% of the Cost of Coverage

• The Program Must Be Reasonably Designed to Promote Health or Prevent Disease

• The Program Must Give Individuals an Opportunity to Qualify for the Reward at Least

Once a Year

• The Reward Must Be Available to All Similarly Situated Individuals

• The Plan Must Disclose That Alternative Health-Contingents (Or Waivers) Are Available



The Reward Must Be No More Than 30% of the Cost of Coverage

• The reward, combined with any other rewards for Health-Contingent based programs provided

under the same plan, must not exceed 30% of the cost of coverage.

• When determining the maximum permissible reward, the full cost of the relevant coverage,

including both the employer and employee-paid portions are counted.

• The 30% limit on health-based incentives is increased to 50% if related to tobacco-use.

• The reward can be in the form of a discount or rebate of a premium or contribution, a waiver of

all or part of a cost-sharing mechanism (such as a deductible, co-payments, or co-insurance),

the absence of a surcharge, or the value of a benefit that would otherwise not be provided

under the plan.

• If only the employee may participate in the wellness program, then the reward must not exceed

30% of the cost of employee-only coverage.



The Program Must Be Reasonably Designed to Promote Health or Prevent

Disease

A program meets this requirement if it:

• has a reasonable chance of improving the health of, or preventing disease in,

participating individuals

• is not overly burdensome

• is not a subterfuge for discriminating based on a health factor

• is not highly suspect in the method chosen to promote health or prevent

disease



The Program Must be Reasonably Designed to Promote Health or Prevent Disease

• There does not need to be a scientific record that the chosen method promotes wellness, and this

requirement is intended to be easy to satisfy and prohibits bizarre, extreme, or illegal requirements in a

wellness program.

• There are examples in in the final regulations that serve as safe harbors, so that an employer can adopt a

program identical to one described as satisfying the example and be assured of satisfying the

requirements in the regulations.

• Wellness programs similar to the examples also would satisfy the reasonably designed requirement.

• Plans or issuers should not feel constrained by the relatively narrow range of programs described by the

examples but want plans and issuers to feel free to consider innovative programs for motivating individuals

to make efforts to improve their health.

• This determination must be based on all relevant facts and circumstances.



The Program Must Give Individuals an Opportunity to Qualify for the Reward at Least Once a Year

• This is a bright-line Health-Contingent that establishes a minimum frequency of qualification opportunities.

• A program could offer more frequent qualification opportunities, but not less frequent opportunities.

The Reward Must Be Available to All Similarly Situated Individuals

• It means that that both the general Health-Contingent for grouping “similarly situated individuals” must be

satisfied, and that a reasonable alternative generally must be provided.

• Certain groups of individuals may be treated as distinct similarly situated groups if the distinction is based

on a bona fide employment classification (such as full-time versus part-time status, current employees

versus former employees, and different geographic locations).

• A reward could be offered to a group of employees (but not retirees), or a group of employees from one

location but not those from another location.

• Similarly, a reward could be offered only to employees and not to spouses or dependent children, or only

to employees and spouses and not to dependent children.




• For activity based programs, a reward is not available to all similarly situated individuals unless

the program allows a reasonable alternative standard (or waiver of the applicable standard) for

any individual for whom it is either unreasonably difficult due to a medical condition to satisfy the

otherwise applicable standard or medically inadvisable to attempt to satisfy the otherwise

applicable standard.

• For activity-only programs, it is permissible for a plan to require verification (such as a statement

from the individual’s personal physician) that the individual has such a medical condition, but

only if it is reasonable under the circumstances.

• It is reasonable to require such verification if medical judgment is required to evaluate the

validity of a request for a reasonable alternative standard.




• Outcome-based programs: If an individual does not meet a plan’s target standards for out come based

programs based on a measurement, test, or screening related to a health factor, the individual must be

provided with a reasonable alternative standard, regardless of any medical condition or other health status,

to ensure that outcome based initial standards are not a subterfuge for discrimination or underwriting

based on a health factor.

• For outcome-based programs, the reasonable alternative standard cannot be a requirement to meet a

different level of the same standard without additional time to comply that takes into account the

individual’s circumstances.

• An individual must be given the opportunity to comply with the recommendations of the individual’s

personal physician as a second reasonable alternative standard to meeting the reasonable alternative

standard defined by the plan, but only if the physician joins in the request.




• Under outcome-based programs, it is not reasonable to require verification that a

health factor makes it unreasonably difficult or it is medically inadvisable for the

individual to satisfy the otherwise applicable standard.

• However, if the reasonable alternative standard to an outcome based program is an

activity-only program, then the plan may seek such verification, if reasonable under the

circumstances, with respect to the activity-only portion of the program.

• The determination of whether a plan has provided a reasonable alternative standard is

based on the facts and circumstances.



The Reward Must be Available to All Similarly Situated Individuals

The following factors, among others, should be taken into account in determining whether a plan has

provided a reasonable alternative standard:

• If the reasonable alternative standard is completion of an educational program, the plan must make the

educational program available or assist the employee in finding such a program, and may not require an

individual to pay for the cost of the program.

• The time commitment required must be reasonable.

• If the reasonable alternative standard is a diet program, the plan is not required to pay for the cost of food

but must pay any membership or participation fee.

• If an individual’s personal physician states that any plan standard (including the recommendations of the

plan’s medical professional) is not medically appropriate for that individual, the plan must provide a

reasonable alternative standard that accommodates the recommendations of the individual’s personal

physician with regard to medical appropriateness.



The Reward Must be Available to All Similarly Situated Individuals

• Plans may always waive the otherwise applicable standard instead of providing a reasonable alternative

standard.

• Additionally, plans do not need to establish a particular reasonable alternative standard in advance of an

individual’s specific request for one, as long as one is provided upon request.

• Reasonable alternative standards may be provided for a class of individuals or on an individual-by-

individual basis.

• The full reward under either an activity-only or an outcome-based program must be available to all similarly

situated individuals.

• Individuals who qualify by satisfying a reasonable alternative standard must be provided the same, full

reward that is provided to individuals who qualify by satisfying the otherwise applicable standard.

• This same, full reward must be provided even if an individual takes some time to request, establish, and

satisfy a reasonable alternative standard.



The Plan Must Disclose That Alternative Health-Contingents (Or Waivers) Are Available

• A health plan must disclose, in all plan materials describing the health-contingent-

based wellness program, that reasonable alternative health-contingents (or the

possibility of waiver of the otherwise applicable health-contingent) are available.

• The disclosure must also include a statement that recommendations of an individual’s

personal physician will be accommodated.

• For outcome-based wellness programs, a similar notice must be included in any

communication that any individual did not satisfy an outcome-based standard.

• If the plan materials merely mention the availability of the wellness program without

describing its terms, then the reasonable alternatives do not need to be described in

the plan materials.



Wellness Programs and Income Tax


A wellness benefit that does not qualify either as an “eligible medical expense” under Code § 213(d) or a

“fringe benefit” under Code §132 is taxable to the employee.

IRS Memo 2016-22031

• Cash and non-cash incentives, payments and rewards paid to an employee are not excludable from an

employee’s taxable income merely because they are paid under an employer wellness program.

• For purposes of income and employment taxes (e.g., FICA and FUTA), the following items are included as

taxable income/wages even if paid under an employer wellness program:

Cash payments (even small amounts such as $10 or $25) for participating in a wellness program.

Non-cash rewards, incentives or other benefits that are not medical care as defined under Code section 213. E.g.,

payment of gym membership, unless, based on the facts and circumstances, it would be a medical expense under

213(d).

Payment or “reimbursements” through a wellness program to reimburse employees for all or a portion of the

premiums the employees paid by salary reduction.

Taxation Issues


IRS Memo 2016-22031

• The following items are excluded from taxable income, whether paid under a wellness program or not:

Benefits, services and non-cash rewards or incentives that are medical care as defined under Code section 213.

E.g., biometric screenings, smoking cessation programs, health risk assessments.

Rewards or incentives that qualify as “de minimis” fringe benefits under Code section 132(e). These are defined as

property or services whose value is so small that accounting for them would be unreasonable or administratively

impracticable. An example would be tee shirts provided under a wellness program.

• Two other employer payments that are also excluded from taxable income but were not addressed under

Tax Memo 201622031 are:

Group health plan premium reduction amounts paid as rewards for employees who participate in or complete

specified activities under the employer wellness program that is connected to the group health plan.

Employers’ H.S.A. contributions for employees who complete specified activities under the employer wellness

program, so long as they meet applicable comparability requirements or cafeteria plan nondiscrimination rules.

Taxation Issues


IRS Chief Counsel Advice 20171925

• Enrolled employees participating in a specified no-cost wellness activities received cash

payments from a fixed payment plan. Such payment exceed their after tax contributions.

• Such payments are taxable.

• Employee also can make substantial pre-tax contributions in a wellness program that

qualified as an accident and health plan and offers no-cast wellness activities.

• Those participating in wellness program also qualify for payments from a fixed payment

plan.

• Those payment may be in cash or flex credits.

• Payments can be taxable.

Taxation Issues


Wellness Programs and ERISA


• It depends.

• To the extent that a wellness program provides medical benefits, it will likely be

treated as a group health plan subject to the special ERISA rules.

• In the DOL Information Letter to Joseph Dunn (November 17, 1993), the DOL

indicated that a wellness program will be considered providing "medical care" if

it provides programs that are diagnostic or preventive, or that "coach" for certain

identified health risks.

Wellness Programs and ERISA


Wellness Programs and GINA


• Underwriting purposes include changing deductibles or other cost-sharing mechanisms or

providing discounts, rebates, payments in kind or other premium differential mechanisms in

return for activities such as completing a health risk assessment (“HRA”) or participating in

a wellness program.

• Family history or other genetic information can be collected if the purpose of such collection

is neither for underwriting purposes nor prior to or in connection with enrollment.

• Genetic information includes the collection of family medical history.

• Any wellness program that provides rewards for completing HRAs that request genetic

information, including family medical history, violates the prohibition against requesting

genetic information for underwriting purposes.

• This is the result even if rewards are not based on the outcome of the assessment.



• Genetic information can be collected as long as no rewards are provided (and if the request is

not made prior to or in connection with enrollment).

• A group health plan or health insurer can provide rewards for completing a HRA as long as the

HRA does not collect genetic information.

• In May 2016, EEOC released regulation how GINA affects wellness programs:

Prior Authorization Required:

• An employer offering an incentive to an employee for the employee’s spouse to complete an HRA

or biometric screening must obtain a voluntary written authorization from the spouse.

• The written authorization must describe the type of genetic information that will be obtained, how

it will be used, and the confidentiality protections on the sale, transfer, and disclosure of the

genetic information.



No gateway plans.

• A wellness program is required be voluntary and reasonably designed to promote

health and prevent disease.

• An employer is prohibited from restricting access to particular benefits based to an

employee or his or her family members based on a spouse’s refusal to provide

information about the manifestation of disease or disorder in an HRA or biometric

screening.

Incentives for child participation prohibited.

• Inducements for information from children of employees are prohibited.

• The prohibition applies to both minor and adult children and to both biological and

adopted children.



Separate Incentives for Employees and Spouses.

• The EEOC does not consider a wellness program to meet the reasonable design requirement if it

penalizes an employee due to a spouse’s failure to participate or achieve a particular health outcome.

• Plans with a spousal participation component must be designed in such a way that an employee may still

receive their own award independent of the spouse’s participation in or results from an HRA or biometric

screening.

Incentives Limited to 30% of the Cost of Self-Only Coverage:

• An incentive provided to a spouse under the final rule is limited to 30% of the total cost of self-only

coverage under the group health plan in which the employee is enrolled, if enrollment is a condition for

participation in the wellness program.

• The GINA final rule provides three additional methods for calculating the maximum permissible incentive in

cases where an employer offers one or more group health plans and enrollment is not a condition of

participation in the wellness program, and where an employer does not offer a group health plan.



The final regulations are effective prospectively as of the first day of the first plan

year beginning on or after January 1, 2017, for the health plan used to determine

the wellness program incentives.

The final regulations apply to wellness programs connected to a group health

plan and stand-alone wellness programs with no connection to a group health

plan.



Wellness Programs and ADA


• In May 2016, EEOC released final regulations how ADA impacts Wellness programs:

• No Gateway Plans:

The EEOC made clear that the ADA prohibits “the outright denial of access to a benefit available by virtue of

employment” and concluded that such plan designs discriminate against the employee in violation of 42 U.S.C.

12112(d)(4).

Employers that currently utilize gateway plans should prepare to align their wellness program structure with the

requirements of the final rule.

• There are two rules under the ADA that employers offering wellness and disease-management programs

should consider carefully.

• First, the ADA generally prohibits employment discrimination against disabled individuals.

• A wellness or disease-management program that requires disabled individuals to participate in order to

attain benefits equal to those offered to nondisabled individuals might be found to violate this provision—

even if HIPAA's nondiscrimination requirements are satisfied.

Wellness and ADA


Second, the ADA limits the circumstances under which an employer may require

employees to undergo physical examinations or provide answers to medical

inquiries.

The prohibition on medical examinations or inquiries is subject to some

exceptions, including an exception that permits employers to conduct voluntary

medical examinations and inquiries as part of an employee health program (e.g.,

a wellness or disease-management program that offers medical screening for

high blood pressure, weight control, or cancer detection), provided that

participation in the program is voluntary, information obtained is maintained

according to the confidentiality requirements of the ADA, and the information is

not used to discriminate against an employee.

Wellness and ADA


In May 2016, EEOC released final regulations how ADA impacts Wellness programs:

New Notice Requirement:

• For a wellness program to be considered voluntary, employers must meet certain conditions.

• One of these conditions is a new notice requirement.

• Employees participating in wellness programs that involve disability-related inquiries or medical

examinations must be given a notice that describes

the type of information to be collected

the purpose for which the information will be used

the restrictions on disclosure of the information

any employer representatives or other parties with whom the information will be shared

the methods used to ensure the information will not be improperly disclosed

Wellness and ADA


Incentive Limitations – Not Tobacco Related:

• The final rule retains the 30% cap on incentives but clarifies how the limitation must be

calculated.

• The limitation is based on the cost of self-only coverage.

• The calculation methods in the final rule address four scenarios:

incentives provided to employees when participation in the wellness program is limited to employees

enrolled in the plan

incentives provided to employees when the employer offers only one group health plan and

participation in the wellness program is offered to all employees regardless of enrollment

incentives provided to employees when the employer offers more than one group health plan and

participation in the wellness program is offered to all employees regardless of enrollment

incentives provided to employees when the employer does not offer a group health plan

Wellness and ADA


Incentive Limitations – Tobacco Related:

• Under the EEOC final rule, a program would be subject to a total incentive cap

of up to 30% of the cost of self-only coverage.

• This limitation applies if the program involves a medical examination, like a

cotinine test administered as part of a biometric screening or on a stand-alone

basis.

• A wellness program that merely asks an employee whether or not they use

tobacco is not subject to the lower 30% limitation.

Wellness and ADA


Confidentiality:

• The final rule reiterates the ADA’s confidentiality protections for medical records.

• Generally, wellness programs that are connected to a group health plan or wellness programs that meet

the definition of a group health plan are subject to HIPAA’s privacy and security protections.

• The EEOC’s interpretive guidance states that it is likely wellness programs that must comply with HIPAA’s

Privacy Rule will also be compliant with the ADA’s confidentiality protections.

• However, for wellness programs that are not subject the HIPAA, the EEOC’s final rule clarifies the

confidentiality protections that apply to such a program.

• Under these protections, employers offering wellness programs subject to this final rule are only permitted

to receive information collected as part of the wellness program in aggregate form that does not disclose,

and is not reasonably likely to disclose, the identity of specific individuals except as necessary to

administer the plan or as permitted by the regulations.

Wellness and ADA


• The final regulations are effective prospectively as of the first day of the first plan year beginning

on or after January 1, 2017, for the health plan used to determine the wellness program

incentives.

• The final regulations apply to wellness programs connected to a group health plan and stand-

alone wellness programs with no connection to a group health plan.

Wellness and ADA


• The validity of the EEOC’s final regulations has been challenged in court.

• In August 2017, a federal court found that the EEOC’s interpretation of the ADA’s “voluntariness”

requirement was not reasonable or supported by the administrative record created during the

rulemaking process.

• Specifically, the court held that the EEOC had not justified its conclusion that a 30% incentive

level is a reasonable interpretation of the term “voluntary” in the ADA.

• The AARP litigation does not affect the validity of the HIPAA regulations.

• AARP v. EEOC, 2017 WL 6542014 (D.D.C. 2017)

Wellness and ADA


• In December 2017, the federal court that sent the EEOC’s final wellness regulations back to the

agency for reconsideration after finding the incentive provisions arbitrary and capricious, has

now vacated those portions of the regulations effective January 1, 2019.

• The court declined AARP’s request to block their enforcement before that date.

• Plan sponsors must continue to comply with the regulations currently in effect

• The EEOC indicated it intended to propose revised regulations by August 2018, with final

regulations likely not applicable until 2021

• Available at https: https://ecf.dcd.uscourts.gov/cgi-bin/show_public_doc?2016cv2113-55

Wellness and ADA


https://ecf.dcd.uscourts.gov/cgi-bin/show_public_doc?2016cv2113-55

ACA


Grandfathered status:

• The various federal agencies caution that penalties related to wellness programs (such as cost-sharing

surcharges) should be examined carefully as they could jeopardize the plan's grandfather status-for

example, by decreasing the employer's contribution percentage by more than 5 percentage points below

the contribution rate on March 23, 2010.

Employer Mandate:

• To avoid the employer mandate penalty, premiums for coverage may not exceed 9.56% of the

employee’s household income in 2018.

• The IRS has proposed that the affordability of an employer-sponsored plan is determined by assuming that

each employee fails to satisfy the requirements of a wellness program, except the requirements of a

nondiscriminatory wellness program related to tobacco use.

• The affordability of a plan that charges a higher initial premium for tobacco users will be determined based

on the premium that is charged to non-tobacco users, or tobacco users who complete the related wellness

program, such as attending smoking-cessation classes.

ACA


Company Background - Services

48

Eligibility

Enrollment

Integration

Self Service

Communications

EE Call Center

Decision Support

Retiree H&W Admin.

COBRA

Direct Billing

Total Rewards

Reimbursements (HSA / FSA)

Commuter Benefits

Dependent Verifications

ACA & Other Compliance Svc.

We help participants understand and use

their benefits wisely so that they can be

accountable for their healthcare.

We enable you, as the plan sponsor, to

enable and deliver your benefits strategy.

benefit wise. relationship driven.


Company Background – Book of Business

49

Clients & Services Supported

226

Administration Participants 1,500,000+

3,952Technology Clients

Reimbursement / COBRA clients 187

Average client size - participants 4,100

Mid/Large Administration clients

ACA 1095 Forms Generated 250,000

250 employees serving our clients from two services

center; Schaumburg, IL and Rancho Cordova, CA.


Some of Our Partners


Questions?


Contact Information

52

Larry Grudzien

Attorney at Law

(708) 717-9638

[email protected]

www.larrygrudzien.com


mailto:[email protected]

http://www.larrygrudzien.com/

Recruiting & HR

Wellness Plan Success: Essentials of Compliance and Engagement