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HR Focus - January 2014
1. HUMAN CAPITAL PRACTICE
HRFocus
January 2014
www.willis.com
HR CORNER
MOST WORKERS INTEND TO ACTIVELY SEEK
A NEW POSITION IN 2014, SAYS POLL
This article provided by BLR
A majority of workers intend to actively seek a new position in
2014, according to a recent poll.
According to the Right Management poll, only five percent of
employees intend to stay in their current position.
The latest findings, shown below, are consistent with results from
the last four years.
DO YOU PLAN TO PURSUE NEW JOB OPPORTUNITIES
IN 2014?
2013
2012
2011
2010
2009
83%
86%
84%
84%
60%
Maybe, so I’m
networking.
9%
8%
9%
8%
21%
Not likely, but I’ve
updated my resume.
3%
1%
2%
3%
6%
No, I intend to stay in
current position.
5%
5%
5%
5%
13%
Yes, I intend to actively
seek a new position.
“These numbers should signal a wake-up call for top
management, when four out of five employees say they intend
to look for employment elsewhere. Solutions to keeping the best
talent on board all point to effective engagement that drives
performance, satisfaction and loyalty. Employers must act now
to engage top talent and prevent them from leaving for the
competition,” said Scott Ahlstrand, Right Management’s global
practice leader for employee engagement.
Right Management surveyed 871 employees in the U.S.
and Canada via an online poll that ran from October 16 to
November 15, 2013.
HR CORNER
Most Workers Intend to Actively seek a
New Position in 2014, Says Poll������������������������������������������������������� 1
Survey: Half of Companies Plan to Invest
More in Training in Reaction to Skills Gap�������������������������������������� 2
HEALTH OUTCOMES
Revitalize your wellness program in 2014���������������������������������������� 3
LEGAL COMPLIANCE
CMS Creditable Prescription Drug Coverage: Filing Reminder�������� 4
Wellness Incentives – Requiring Employees and
Spouses to Meet the Wellness Standard����������������������������������������� 4
COBRA Premiums and Working Spouse Contributions�������������������� 5
WEBCASTS.............................................................................6
CONTACTS..............................................................................7
Willis North America | January 2014
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2. HR Corner – continued from page 1
SURVEY: HALF OF COMPANIES PLAN TO
INVEST MORE IN TRAINING IN REACTION
TO SKILLS GAP
This article provided by BLR
In a recent survey, 51 percent of employers indicated they plan
to increase their investments in training over the next two years.
In addition, 35 percent of surveyed executives at companies that are
facing a skills shortage acknowledge that they have not made a big
enough investment in training in the past.
The “Accenture 2013 Skills and Employment Trends Survey:
Perspectives on Training” (www.accenture.com/SkillsGap)
confirmed that the skills gap remains a problem for employers—with
46 percent of executives concerned that they will not have the skills
needed in their business within the next few years.
When asked to identify ways for employees to develop new skills,
72 percent of executives pointed to training. Only 52 percent of
employees working at the surveyed companies currently receive
formal training from their employers. However, that number is more
than double the figure from a previous Accenture survey in which
only 21 percent of U.S. workers reported being formally trained by
their employer between 2006 and 2011.
The consequences of not addressing the skills gap are significant,
with 66 percent of those facing or anticipating a skills shortage
expecting to lose business to their competitors as a result. Other
concerns include loss of revenue (64 percent), eroding customer
satisfaction (59 percent), and a delay in developing new products or
services (53 percent). In addition, the survey found that 87 percent
of companies’ existing employees are facing additional pressure and
stress due to the inability to train employees with new skills or to hire
workers who already possess needed skills.
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Willis North America | January 2014
“It’s clear that U.S. businesses are looking to
take a more active role in solving the skills
challenge, and that failing to do so can result
in significant business consequences,” said
David Smith, senior managing director
of Accenture Talent Organization.
“Developing more effective and targeted
training programs is a critical element in
improving the skills of the workforce.”
“As digital technology blurs the boundaries
between formal and informal learning,
companies should consider ways to strike
a balance between the two and help ensure
that they work in tandem,” Accenture
stated. “For instance, embedding learning
in everyday work—shadowing others,
mentorships, or learning from peers
through online forums—can help formal
online or classroom training becomes more
relevant and more effective.”
The survey also found that employers
continue to use new methods to deliver
employee training: mobile delivery (used
by 42 percent of survey respondents),
social media (35 percent), massive open
online courses (MOOCs) (27 percent), and
gamification (13 percent).
3. HEALTH OUTCOMES
REVITALIZE YOUR WELLNESS PROGRAM
IN 2014
Want to refresh your current wellness program? First, you want
to consider the program options and design that make sense for
your worksite. An effective, sustainable worksite wellness program
is one that is comprehensive and customized to your employees.
A successful program is one that grows each year to continually
engage and maximize participation. A common challenge that
many employers face is when a wellness program becomes stale or
repetitive. Below are a few quick, simple and free ideas to help get
your program energized in the New Year.
Conduct an informal focus group. Drop in staff meetings and ask
employees what they are interested in hearing about and how they
prefer to receive updates on worksite wellness offerings. Ask them
about any incentives you may be considering for the future or how
they feel things have been going so far with your wellness strategy.
Surprise your employees. Make them laugh and focus on some
new ways to communicate. Consider posting a blog, starting a
Facebook page for your program or sending text message reminders.
Use sidewalk chalk messages by the entrances to liven things up.
Leave notes or surprises in people’s work areas. Invite managers and
supervisors to share a “weird but true” health tip before the start of
every staff meeting.
Share a personal story. Invite someone from your senior
leadership to share their personal story about a successful health
change they have made or a challenge they are currently working
on. Sharing with your employees that we all have personal health
goals we need to work on and that it is hard to change behaviors will
help build a culture of health in the workplace. Invite others to share
their stories for future communications.
Build a Wellness Buddy Program. Invite those that seem to
always attend or participate in wellness programs to bring a
buddy in order for both of them to earn extra recognition. Noting
participant names publically, sharing an event picture album or even
printing out a homemade certificate can go a long way to helping
people feel they are engaged and part of something positive.
Make it family friendly. Promote a
community walk or bike ride and encourage
employees to bring their families. These
events can become annual activities that
people look forward to. Also, remember to
share information in your communications
about healthy options that appeal
to parents, grandparents, aunts and
uncles, such as tips for getting kids more
active, packing healthy lunches, making
wholesome snacks and guidance for dealing
with bullying and self-esteem issues.
Doing something, even on a small scale, can
often help you kick start the momentum
towards a more comprehensive, long-term
investment in a healthier workforce. To
learn more about the resources and tools
available to help you get started, contact
your Willis client service team.
Willis North America | January 2014
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4. LEGAL COMPLIANCE
CMS CREDITABLE PRESCRIPTION DRUG
COVERAGE: FILING REMINDER
The Medicare Prescription Drug Improvement and Modernization
Act of 2003 requires all plan sponsors – even those who did not
provide retiree prescription drug benefits – to distribute notices
to Part D-eligible individuals explaining the creditable coverage
status of their prescription drug benefits. This notice tells recipients
whether or not the plan’s prescription drug coverage is considered
“creditable” as measured against Medicare’s Part D standard
prescription drug benefit. Creditable status is important, since a
Part D-eligible individual will be assessed a Part D late enrollment
fee if he or she initially waives enrollment in Medicare’s prescription
drug benefit and later enrolls after a break in creditable coverage of
63 days or longer.
Additional Reporting Duty to CMS
A second and perhaps more easily overlooked disclosure
requirement is that group health plan sponsors providing
prescription drug coverage to Medicare Part D-eligible individuals
must also report creditable status directly to CMS. Specifically, the
group health plan must communicate whether its prescription drug
coverage qualifies as creditable or non-creditable. The government
needs this information in order to effectively coordinate Medicare
Part D enrollment.
All plan sponsors providing prescription drug coverage are required
to make this disclosure – even if they do not make coverage available
to retirees. Reporting to CMS about the plan’s creditable status is
due within 60 days after the first day of the new plan year. Calendaryear plans must submit the disclosure to CMS by March 1, 2014.
Additional information about the CMS reporting duty is also
available on Willis Essentials.
WELLNESS INCENTIVES – REQUIRING
EMPLOYEES AND SPOUSES TO MEET THE
WELLNESS STANDARD
Plan sponsors frequently want to design a wellness program that
does more than merely provide an opportunity for spouses to
participate in a wellness program. Many would like a plan that looks
similar to one of the following:
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Willis North America | January 2014
ƒƒ The plan is based on a health-contingent
wellness program that provides
incentives for completion of activityonly and outcomes-based wellness
programs. The incentive would be
earned only when both employee and
spouse achieve the standard/complete
the activity. So, in cases where the
employee elects coverage for himself
and his spouse, but only the employee
participates in the wellness program,
the plan sponsor would not provide any
wellness discount.
Or:
ƒƒ The plan sponsor averages the wellness
scores across all family members, and
a wellness award is based upon the
average score obtained by the family.
Unfortunately, these wellness plan designs
for health-contingent wellness programs
must be considered carefully and only
adopted with the concurrence of legal
counsel since the publication of the final
wellness regulations. Under the final
regulations, when a health-contingent
wellness incentive is offered, each family
member who is eligible to participate
in the wellness program must have a
separate opportunity to qualify for the
reward. However, if the wellness reward
is withdrawn for participating family
members because another family member
did not participate in the wellness program,
then the plan has not actually offered each
separate individual the ability to participate
in the wellness program.
In the past, some employers have used this
type of an “all or nothing” wellness program
design as a means to add a behavioral
economics tool – sometimes called “social
norming.” The tool is designed to augment
the financial incentive so that the incentive
can change health behaviors.
Continued on page 5
5. Legal Compliance – continued from page 4
The new guidance confirms that if a plan sponsor wants to use a
family incentive within a health-contingent wellness program, any
family incentive must be “apportioned” in a “reasonable” manner.
Where a spouse or children participate in the wellness program, the
applicable rate for determining the maximum financial incentive
would be the tier that the employee elected (employee + 1, employee
plus spouse, full family). However, where one family member
meets the requirements but another does not, the incentive is to
be adjusted. The guidance is vague and states that “…these final
regulations do not set forth detailed rules governing apportionment
of the reward under a health-contingent wellness program. Instead,
plans and issuers have flexibility to determine apportionment
of the reward among family members, as long as the method is
reasonable.” 78 Fed. Reg. 33158, 33162. The meaning of “reasonable”
is determined under a facts and circumstances test. If a healthcontingent plan design is offered, the most cautious approach would
be to pro-rate the family incentive among the participating family
members.
COBRA PREMIUMS AND WORKING SPOUSE
CONTRIBUTIONS
If an employee’s spouse is offered coverage through his/her own
employer and the spouse declines that coverage, some plans require
that the employee pay a “working spouse” contribution in addition
to the regular premium contribution that the plan requires for
that dependent. The purpose of this contribution or surcharge
is to discourage dependent spouses from waiving their employer
coverage and instead require the spouse’s plan to pay for its fair
share of the spouse’s health coverage as the primary plan. In the
event the employee’s spouse becomes eligible for COBRA, however,
that working spouse contribution cannot be included in calculating
the spouse’s COBRA premium, regardless of whether the coverage
is being provided through an insured or a self-funded plan. The plan
cannot charge a COBRA premium that is greater than the cost to the
plan for coverage of similarly situated beneficiaries, plus 2% to cover
the plan’s administrative costs.
For insured benefits, the plan should
charge the same premium rate that the
insurance company charges (plus a 2 %
administrative fee) by looking to the same
groups and group rates that the insurer
used to determine premiums – for example,
rates that vary by family unit or region
where the employee resides. The COBRA
premium rate structure should mirror the
insurer’s rate structure, and since insurers
do not surcharge for spouses who have
coverage through their employers (and are
probably prohibited from doing so under
state insurance law), a working spouse
surcharge would likely violate COBRA law.
In addition, under ERISA Section 604, selffunded plans are required to use a COBRA
premium that is a reasonable estimate of
the cost of providing the health coverage,
determined on an actuarial basis or based
on the plan’s costs for the preceding
determination period (plus a cost-of-living
adjustment). The cost for a health plan to
provide coverage to an employed spouse
is the same as the cost for a health plan
to provide coverage to an unemployed
spouse. Therefore, the additional cost to
the sponsor’s plan caused by the working
spouse not enrolling in his/her employer’s
plan is not the type of cost that the law
considers appropriate for inclusion in
the COBRA premium. For this reason,
inclusion of a working spouse surcharge in
the COBRA premium of a self-funded plan
would likely violate COBRA law.
Willis North America | January 2014
5
6. WEBCASTS
HEALTH CARE REFORM SHARED
RESPONSIBILITY DELAY: ARE YOU
USING IT TO YOUR ADVANTAGE?
EXCHANGES – PUBLIC AND PRIVATE – WHO
ENROLLED, WHAT’S NEXT?
Tuesday, January 21, 2014
2:00 PM Eastern
Presented by:
Rob Harkins
Vice President of Private Exchanges
Willis Human Capital Practice
Jay Kirschbaum, JD, LLM, FLMI
Practice Leader
National Legal and Research Group
Willis Human Capital Practice
Exchanges have been a hot topic in the last year; however,
questions remain. How have public exchanges impacted employer
health care to date? Are private exchanges set up to be successful
long-term? Join us as we review today’s public and private
exchange marketplace.
During this event, we will:
ƒƒ Discuss why many companies are considering private exchange
models, and potential advantages and obstacles to weigh when
exploring if a private exchange is a good fit for your organization
ƒƒ Review employer attributes of early public exchange adopters
and lessons learned from these organization
ƒƒ Explore the financial plusses and minuses when considering a
private exchange and strategies to control cost
ƒƒ Review the ins and outs of a Private Exchange – How to Administer
a Private Exchange under ERISA, HIPAA, the IRC, etc.
To RSVP, click here.
NOTE: Advance RSVP is required to participate in this call.
Registration ends one hour prior to the call start time.
Tuesday, February 18, 2014
2:00 PM Eastern
Presented by:
Jimmy Phillips
National Practice Leader
Reporting and Analytics Consulting
Human Capital Practice
By now we are all aware of the recent delays
associated with the PPACA employer
mandate. Some organizations may use the
delay to wait another year before evaluating
the impact this law will have on their
business. However, as someone wisely
observed, “A year from now you may wish
you had started today.” Join us to learn how
to take advantage of the delay using a more
strategic approach.
During this session, participants will learn:
ƒƒ What financial and data analysis is
necessary to understand the cost
impacts on an organization’s
pay-or-play decision
ƒƒ What organizations should do between
now and 2015 to best prepare for
ongoing PPACA regulations
ƒƒ How PPACA may impact an
organization’s Human Capital strategy
and overall business results
To RSVP, click here.
NOTE: Advance RSVP is required to
participate in this call. Registration ends
one hour prior to the call start time.
This program has been approved for 1 recertification hour toward PHR, SPHR and GPHR recertification
through the Human Resource Certification Institute (HRCI). For more information about certification or
recertification, please visit the HRCI homepage at www.hrci.org. This applies to both Webcasts.
6
Willis North America | January 2014
7. KEY CONTACTS
U.S. HUMAN CAPITAL PRACTICE OFFICE LOCATIONS
NEW ENGLAND
ATLANTIC
Auburn, ME
207 783 2211
Baltimore, MD
410 584 7528
Bangor, ME
207 942 4671
Knoxville, TN
865 588 8101
Boston, MA
617 437 6900
Memphis, TN
901 248 3103
Burlington, VT
802 264 9536
Metro DC
301 581 4262
Hartford, CT
860 756 7365
Nashville, TN
615 872 3716
Manchester, NH
603 627 9583
Norfolk, VA
757 628 2303
Portland, ME
207 553 2131
Reston, VA
703 435 7078
Shelton, CT
203 924 2994
Richmond, VA
804 527 2343
NORTHEAST
Rockville, MD
301 692 3025
Buffalo, NY
716 856 1100
SOUTHEAST
Morristown, NJ
973 539 1923
Atlanta, GA
404 224 5000
Mt. Laurel, NJ
856 914 4600
Birmingham, AL
205 871 3300
New York, NY
212 915 8802
Charlotte, NC
704 344 4856
Norwalk, CT
203 523 0501
Gainesville, FL
352 378 2511
Radnor, PA
610 254 7289
Greenville, SC
704 344 4856
Wilmington, DE
302 397 0171
Jacksonville, FL
904 562 5552
Marietta, GA
770 425 6700
Miami, FL
305 421 6208
Mobile, AL
251 544 0212
Orlando, FL
407 562 2493
Raleigh, NC
704 344 4856
Savannah, GA
912 239 9047
Tallahassee, FL
850 385 3636
Tampa, FL
813 281 2095
Vero Beach, FL
772 469 2843
MIDWEST
Appleton, WI
800 236 3311
Chicago, IL
312 288 7700
Cleveland, OH
216 861 9100
Columbus, OH
614 326 4722
Detroit, MI
248 539 6600
Grand Rapids, MI
616 957 2020
Willis North America | January 2014
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8. Milwaukee, WI
262 780 3476
McAllen, TX
956 682 9423
Minneapolis, MN
763 302 7131
763 302 7209
Mills, WY
307 266 6568
Moline, IL
309 764 9666
Pittsburgh, PA
412 645 8506
Schaumburg, IL
847 517 3469
SOUTH CENTRAL
Amarillo, TX
806 376 4761
Austin, TX
512 651 1660
Dallas, TX
972 715 2194
972 715 6272
Denver, CO
303 765 1564
303 773 1373
Houston, TX
713 625 1017
713 625 1082
New Orleans, LA
504 581 6151
Oklahoma City, OK
405 232 0651
Phoenix, AZ
602 787 6235
602 787 6078
Portland, OR
503 274 6224
Rancho/Irvine, CA
562 435 2259
Overland Park, KS
913 339 0800
San Diego, CA
858 678 2000
858 678 2132
San Antonio, TX
210 979 7470
San Francisco, CA
415 291 1567
Wichita, KS
316 263 3211
San Jose, CA
408 436 7000
WESTERN
Seattle, WA
800 456 1415
Fresno, CA
559 256 6212
Irvine, CA
949 885 1200
Las Vegas, NV
602 787 6235
602 787 6078
Los Angeles, CA
213 607 6300
The information contained in this publication is not intended to represent legal or tax advice and has been prepared solely for
educational purposes. You may wish to consult your attorney or tax adviser regarding issues raised in this publication.
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