In the wellness industry, 2018 is ending just like it began: Vendors Behaving Stupidly.
Along with about 12 other need-a-lifers, we traditionally attend a “Nerd-a-Thon” on New Years Eve (tonight), where we play board games, including home Jeopardy. One Jeopardy answer might be:
A: “Roughly 3 seconds.”
The correction question would be:
Q: “What is the length of time required for a beam of light leaving intelligence to reach Interactive Health?”
Yes, Interactive Health is ending the year just as they began it, by setting new standards for cluelessness. They started the year by offering unsuspecting and no doubt somewhat befuddled employees a “smoking recession program,” and are ending it by proving that their 2017 and 2018 Deplorables Awards were well-earned.
Here is their posting:
Let’s look at it carefully. They crammed four mistakes/fallacies, plus a unique hashtag (#HealthareCosts) into two lines. First, anemia is not “33% more likely” among women under 45. To the contrary, if they had wanted to step out of character and make an actual true statement, it would have been pretty much the opposite: “Women 15 to 40 are 26% less likely to be anemic than women 40 to 69.”
Perhaps this information will come as much of a surprise to them as it did to me — the difference of course being that I didn’t just post the opposite to 12,162 chronically misinformed followers.
There is an asterisk in case anyone is keeping score at home — pregnant women of any age are at higher risk for anemia. That is the most clinically significant factoid about anemia in the working-age population, a factoid which naturally Interactive Health overlooked. One of their specialties is finding issues that don’t exist while overlooking issues that do. Another one of their specialties is posting random statistics on Linkedin that even a college intern could debunk. Or hyperventilating that the number of cases of Alzheimer’s is expected to double by 2060 without mentioning that the senior population as a whole is expected to double by that year as well. They also claimed that there was a dramatic increase in heart attacks, but in reality the actual rate is about half what it was 40 years ago.
Another possibility is that this anemia data isn’t a surprise at all to them. They are aware of it (it is pretty easy to come by), but telling the truth would have undermined their new revenue enhancement strategy, which is to convince companies to screen the stuffing out of millennials, by “debunking” the “commonly held misperception” that you should adhere to well-resesarched, widely accepted, official US Preventive Services Task Force (USPSTF) clinical guidelines, guidelines which say, unsurprisingly, that you should definitely not screen the stuffing out of millennials.
Second, it doesn’t cost $10,000/year to treat iron-deficiency anemia. It costs about 5-10 cents a day, or $36.50 a year. So Interactive Health is off by a factor of 300. That’s a lot even for them.
Oh, wait, maybe they were talking about hospitalizations for anemia, not garden-variety anemia. Hospitalizations would cost $10,000 or more. However, in the immortal word of the great philosopher Rick Perry, Oops. Looks like young women have far fewer hospitalizations than older women:
To help Interactive Health interpret this data since apparently they could use some assistance, 32.1 admissions per 100,000 women 18 to 44 means 0.3 admissions per 1000 female employees in that age bracket.
In other words, nobody. The average company with 20,000 to 40,000 total employees of normal age and gender distribution would probably have 1 admission for anemia.
And we would bet that whoever is hospitalized for anemia already knew they had anemia before Interactive Health started harassing them. My guess is most of these admission longshots would be either complications of pregnancy or anemia of unknown origin, or a rare disease.
Third — no surprise given that statistic — the USPSTF does not recommend lining up women to be screened for iron-deficiency anemia. (Even for pregnant women, who are at much higher risk than non-pregnant women, they find insufficient evidence to screen them.) “Hunting for disease,” which my colleague Alan Cassels has written extensively about, is rarely a good idea, and this is no exception — which is one reason it isn’t recommended.
Finally, why screen for something that you can’t easily address if someone fails the screen? The other reason it isn’t recommended is that iron supplements for women who are technically anemic but have no symptoms also aren’t a good idea. Liquid iron, like this…
…can, among its many other charming attributes, blacken your teeth. (The good news is that, as the label says, this supplement is gluten-free!) Iron supplementation in general can cause side effects like nausea, vomiting, and diarrhea, while high doses are so downright dangerous that iron pill overdoses are the #2 reason for emergency room visits among all vitamin and mineral supplements.
The good news is, here is another Jeopardy A&Q:
Q: “What is the likelihood that in 2019 Congress is going to pass a law preventing vendors from penalizing employees who refuse to participate in non-USPSTF-recommended wellness screens like Interactive Health’s?”
Breaking: EEOC wellness rule change now officially set…and Trump nominee withdraws, meaning no new rules coming in 2019
For the wellness industry’s “pry, poke and prod” vendors — Interactive Health, Wellsteps, Bravo, Wellness Corporate Solutions etc. — the Grinch has got nothing on the EEOC. For the second year in a row, the EEOC is spoiling their Christmas.
But wait…there’s more
And it looks like the EEOC might also miss their latest self-imposed deadline for proposing new rules, which is June 2019. (The interval from proposing rules to implementing them is measured in months, if not years.) The reason for this? The EEOC still hasn’t filled its open positions and may not have a quorum for rule-making in time to do this. Not to mention they have other fish to fry once they do.
Today, President Trump’s nominee, who would have created the quota, pulled his name from consideration. That makes the likelihood of a quorum for rule-making all the more remote.
So, as Bravo aptly put it in their letter begging Senators to allow them to continue to harass employees with forced screenings, any employer not using Quizzify’s elegantly designed indemnification or other solution faces the “Wild West of litigation” in 2019. And to these vendors I say: Happy Festivus.
If you won a Quizzify health literacy trivia contest in 2018, you should be getting a “ping” from Linkedin right now, as I just posted the rules for finalists to win the Martha’s Vineyard vacation. If you are NOT getting that ping right now, and think you are in the finals, please let us know posthaste.
Otherwise, sign your organization up to host a trivia contest in 2019 so you can try your luck next year.
Does wondering how Quizzify got started keep you up at night? Wonder no longer.
It was not obvious to combine overdiagnosis with Jeopardy. That is, unless you were both on Jeopardy, and also were overdiagnosed, which describes me.
In 2012 I was hired to host a radio series for the NPR affiliate in Washington DC (The Big Fix). After the first taping, the producer said so far so good, but I’d sound better after I got over my cold. Unfortunately, I didn’t actually have a cold. Newsflash to those of you who have heard me on podcasts by Josh Luke, David Contorno/Jeff Bernhard, Jen Arnold, Zeev Neuwirth, or anywhere else: this is the way I sound. I’ve been told I have a face for radio and a voice for newspaper.
Nonetheless, not wanting to be fired my first day on the job, and recalling that a few years earlier a doctor told me I had a deviated septum (“we ought to do something about that”), I immediately called my PCP for advice.
My PCP immediately set up an appointment to see an ENT, who determined that my stuffiness was likely being caused not by the deviated septum, but rather by a raging case of the polyps. (“Your deviated septum is the least of your problems.”)
The ENT suggested surgery, Flonase, or Flonase combined with a three-week course of antibiotics. “So,” she asked after quite literally six minutes explaining the options, “which do you want to do?”
“Um, shouldn’t we do the most conservative therapy first?” I inquired.
“Well, you could,” she replied, using a tone of voice implying that only an imbecile would.
For this year’s Deplorables Award, the winners were given a chance to fact-check in advance, and declined. No need for them to have wasted the effort — only one person, Keith McNeil, has ever found a material mistake in any They Said What posting
As in past years, we convened our panel of distinguished judges to address the age-old question about “pry, poke and prod” wellness programming: how is this stuff even legal?
After they get done contemplating that — and wondering why they’re the only people in the industry who seem to have ethics, an internet connection, and a triple-digit IQ — the judges reviewed the candidates for the coveted Deplorables Award. While any wellness vendor is eligible, they ruled out It Starts with Me, and US Preventive Medicine, since those vendors, whose claims are validated by the Validation Institute, apparently didn’t get the memo that you can’t succeed in this business without lying.
Ruling out those two dramatically narrowed the field down, to only about 1000. Narrowing the field even more, a few, like Provant, took themselves out of the running by going bankrupt. (Individuals are not eligible for the Deplorables Award, so we also need to rule out Ron Goetzel, despite his best efforts to make a late run at the trophy.)
This year, as in previous years, it boiled down to a battle between the very stable geniuses at Interactive Health vs. the people with very good brains at Wellsteps — more than coincidentally the 2017 and 2016 winners respectively. It was a close one. There are very fine people on both sides. Together with Mr. Goetzel, they constitute the wellness industry’s Axis of Genius.They both fabricate outcomes, flout guidelines, and harm employees, so it came down to a simple race to see who, in the wellness industry’s epidemic of very stable geniusitis, would be Patient Einstein.
The case for Wellsteps is compelling. To begin with, after a few proud possessors of high school diplomas observed that their fabricated ROI model will always return a “savings” of $1359 if you zero out inflation even if the smoking and obesity rates go from 0% to 99%, in 2018 they reprogrammed the model so that instead of always returning a “savings” of $1359 in the final program year regardless of what assumptions you input, an obvious rookie mistake that only an idiot wouldn’t notice when designing an Excel spreadsheet model, the model will always returns a “savings” of $1356 in the final program year, regardless of what assumptions you input.
Ah, much better, thank you.
Don’t take our word for it. Here it is. Note that for some reason the actual trendline on the graph doesn’t show up any more. You need to read the fine print instead. Here is what happens if you reduce smoking and obesity from 99% to 0%…
…and here’s what happens if your population already has 0 smokers and no obesity, so no improvement is possible:
If those columns of numbers at the bottom of each chart look identical, it’s because they are. This happens no matter what numbers you enter. (You are no longer allowed to enter increases in smoking or obesity like I used to do, so don’t even try. SPOILER ALERT: If you could, you would still get $1356 in savings.)
And, almost a decade after they first posted their ROI model, it still doesn’t calculate an ROI. Hello, do you see an actual ROI on this screenshot? At this point we’d settle for a phony one. (A real ROI estimation model can be found here.)
Their CEO has been featured on They Said What this year, with his take on the National Bureau of Economic Research’s invalidation of wellness outcomes. He accidentally admitted it was valid.
He claims to have spent “11 years in college.” Yet, even though that’s 4 years longer than Bluto Blutarski, he still can’t add the two columns of numbers he published that showed how badly his Koop-award-winning program for the Boise School District failed. Here are those two columns, a comparison of risk factors in the baseline year vs. one year into the Wellsteps program:
Here’s what happens when you actually add his two columns up — turns out there was a dramatic deterioration in Boise schoolteacher health status.
So it looks like that was, to paraphrase the immortal words of the aforementioned great philosopher Bluto Blutarski, 11 years of college down the drain.
The case for Interactive Health is equally compelling. After winning the Deplorables Award last year, they decided to double down on cluelessness, and so in 2018, they started a “smoking recession [sic] program.”
No one could figure out what they were talking about — apparently including the creators of their smoking recession program, who eventually took it off their website. My hunch was that they were trying to get smokers to switch to Parliament, which features a recessed filter, on the theory that the smoke would take longer to get into people’s lungs.
Later in the year they solidified their front-runner status with three more postings.
- A college intern was able to invalidate their claim that younger workers had more mental health issues than older workers, and that therefore you needed to pay Interactive Health to screen them;
- Next came Interactive Health-meets-Barbie, where they told someone whose HRA showed her to be severely anorexic that she was in a “healthy range.” We noted the irony that this is a company that wants to send almost half your employees to the doctor to treat “newly discovered conditions”…and yet here was someone who appeared to really have a condition that needed attention…and they missed it altogether;
- And just last week they cemented their candidacy by providing a cornucopia of misinformation about the EEOC.
That brings us back to the original question: how is it even legal to harm employees and completely disregard clinical guidelines, as these two companies are wont to do? Well, it turns out that, starting in 2019, it may very well no longer be. No, I’m not referring to the EEOC rule change. That will make companies liable to their employees for fining them, but it will still be legal to screen the stuffing out of them.
The good news is that apparently there will be a move afoot in the next session of Congress to prevent wellness companies from attaching penalties to screens that violate US Preventive Services Task Force guidelines — which is to say, most of Interactive Health’s and (according to Wellsteps’ CEO, Steve Aldana, himself), Wellsteps’.
If this bill were to pass, three things would likely happen:
- Employees would improve on health status;
- Employers would save money on wellness;
- Wellsteps and Interactive Health would throw up on Dean Wormer.
At the same time this program was being announced, the campus bakery announced an expanded selected of pastries and desserts for the upcoming academic year.
The bullet points are that diabetes vendors claims credit for savings based on:
- Squirrelly “predictive modeling” of cost reductions that have not yet occurred
- Assuming employees pre-diabetes would almost immediately turn into high-cost diabetics absent their intervention
- Comparing participants to non-participants (why are vendors still pretending this is a thing?)
- Claiming that people are going to keep their weight off
This doesn’t cover their other sleight-of-hand, which is charging via claims instead of admin fees, and positioning that opacity as a feature rather than a bug.
The very stable geniuses at Interactive Health once again put their very good brains on public display
Interactive Health is well on its way to disproving the law of averages.
I’ve never, ever, seen them get the facts straight. This is a very hard feat to accomplish. Just randomly — or by hiring someone who might know a friend smart enough to do searches on the internet — you’d think they could stumble into an accurate statement every so often. In the immortal words of the great philosopher Rick Perry, even a stopped clock is right once a day. But we’re talking about an outfit that can’t tell the difference between a chair and a cigarette, and, speaking of cigarettes, ran a “smoking recession program.”
They also recently wrote that employers should run batteries of medical tests on their youngest and healthiest employees. Due to the likely harms of overdiagnosis and overtreatment, this “protocol” is directly contrary to what the US Preventive Services Task Force, Society of General Internal Medicine, Choosing Wisely and most recently Consumer Reports advise. But what do all those organizations know? Have they ever diagnosed an 80-pound adult as having weight in a “healthy range”? No, but someone at Interactive Health was able to figure that out without even needing to consult any outside experts.
Can Interactive Health spell EEOC?
On Tuesday (12/11), I conducted a very successful and extremely well-attended webinar for the Pittsburgh Business Group on Health, on the upcoming EEOC wellness rule change, and how to make lemonade out of that lemon, which turns out to be spectacularly easy.
An attendee wrote to me to note that a vendor had said exactly the opposite of what I said about the EEOC rule change — that it was no big deal and that employers need only be “compliant with existing regulations.” I replied that, with everything that has been published by me and others explaining the decision in lay terms, no vendor could possibly be that stupid. But after the person disclosed that the vendor in question was Interactive Health, I immediately apologized and asked for the link, which he sent:
Here is a line-by-line deconstruction of their misinformation:
“The EEOC could…reissue the same regulations but provide more appropriate justification for why a 30% incentive is reasonable and voluntary…”
The judge said the opposite: “AARP vs. EEOC’s decision means that the Equal Employment Opportunity Commission must rewrite its definition of “voluntary” to achieve consistency with the dictionary definition.” He was quite clear that forcing employees to choose between (1) suffering a 30% financial forfeiture and (2) having the stuffing screened inappropriately screened out of them by an unlicensed wellness vendor isn’t the slightest bit “reasonable or voluntary.”
Further, if anyone at Interactive Health could find someone smart enough to actually read the EEOC’s January motion, that person could explain to Interactive Health that the EEOC eventually acknowledged that the judge was right. (“The ADA regulation will still require that participation in wellness programs to be voluntary.”)
Even if they hadn’t agreed, it wouldn’t matter. If the judge says you can’t write rules allowing 30% penalties, it’s not OK to then write rules allowing 30% penalties. That’s why we have a judicial system. To determine what is OK and what’s not OK. A simple concept, covered in eighth-grade civics. Surely someone at Interactive Health has a friend somewhere who is smart enough to find someone who can explain that concept to them.
Interactive’s very stable genius is most on display with this advice:
Generally, employees must be offered choices for earning financial incentives. This includes the opportunity to pursue a reasonable alternative if the individual can establish with their personal physician or an allied health professional that the choices offered by the program are not reasonable for the employee due to a health condition.
They say in the stock market, no one is as valuable as the person who is always right except the person who is always wrong, and indeed Interactive Health has inadvertently created a teachable moment.
Here goes. The “reasonable alternative standard” is an Affordable Care Act construct. It has nothing whatsoever to do with the decision in AARP v. EEOC, which defined “voluntary” as written in the Americans with Disabilities Act (and the Genetic Information Non-Discrimination Act). If you did exactly what Interactive Health is suggesting to “comply” with this ruling, you shouldn’t even bother showing up at the trial if you get sued. Just send a check to the plaintiff.
The reason? The decision in AARP v. EEOC — and the ADA and GINA themselves– address specifically involuntary clinical wellness programs. According to those statutes, any “clinical exam or inquiry” must be voluntary. Large fines (or withheld incentives) are anything but voluntary. In their language above, Interactive Health is proposing replacing one involuntary clinical exam (by them) with another involuntary clinical exam (by a doctor) to determine that the first involuntary clinical exam would not be appropriate, and therefore the employee needs to be presented with yet another type of involuntary clinical exam as an alternative. Wrong, wrong, wrong and wrong.
To summarize, someone at Interactive Health needs to find someone smart enough to explain to the company’s employees that replacing one inappropriate test with another will not suffice to comply with a court order that says you can’t perform inappropriate tests.
Someone needs to step up. The good news is, we know there’s at least one adult in the room — that big, strapping 80-pounder.
There is a ton of misinformation circulating, as you can see from the quotes in this article from NPR and Kaiser Health News.
Just this one sentence is wrong in two ways:
The advice they are receiving from benefit consultants ranges widely, from “drop all incentives and penalties” to “stay the course.”
No, you don’t have to drop all or any incentives and penalties. You can still be protected if you offer a Quizzify-type alternative alongside your wellness program.
And whoever is recommending “stay the course” should lose their license to read. There is no scenario in which any in-house corporate counsel of any company offering $500 or more in incentives or penalties could know about this rule change and recommend doing nothing.
The article also notes:
Some employers say they will stick with their existing programs — even if they hit the 30 percent level — because the EEOC is unlikely to challenge companies that stick with the rescinded percentage while they await the new rules.
But here’s the thing. Nobody ever said they were going to “challenge” companies that max the penalties/incentives. They have bigger fish to fry and these days are much more employer-friendly than they once were. (They are also woefully understaffed at the top.) But employees can sue. That’s the issue. The EEOC challenge thing is a total red herring.
Fortunately, there is an elegant solution which will allow you to turn this lemon into lemonade, offered Tuesday 12-11 at noon EST. You can sign up right here. Make sure you have your credit card handy because the free webinars are done. It’s $25 (such a deal) unless you are a member of the Pittsburgh Business Group on Health.
…a cover story in one of the most respected magazines in the US which spells the end of Interactive Health, Wellsteps, Total Wellness, Star Wellness, Wellness Corporate Solutions and every other vendor whose business model is to screen the stuffing out of employees.
Meanwhile, I know of one company where the staff is popping champagne corks. Wonder what that company could be?