In the immortal words of the great philosopher Yogi Berra, it’s tough to make predictions, especially about the future.
However, in this case the future is pretty easy to predict: The EEOC “Safe Harbor” for clinical wellness programs ends in less than 6 months, period. Time is running out in the race to put non-clinical options in place in 2018 (to drive the 2019 premium differential)…and yet many employers, thanks to the obfuscation of their “pry, poke and prod” vendors, don’t even realize the race is on.
Problem is, too many employers listen to their wellness vendors, who largely seem to be missing the gravity of this situation altogether. Mind you, these are the same very stable geniuses who also managed to miss the rehabilitation of eggs, fats, and dietary cholesterol, the entire opioids epidemic, and the part of fifth grade where the teacher explained that a number can’t go up and down at the same time. So naturally they are on track to miss the biggest wellness event since the passage of the Affordable Care Act.
By contrast, the most recent BenefitsPro just devoted its lead article to this impending event. Main takeaways:
- Employers are “not likely” (that’s an understatement) to see EEOC rules allowing a safe harbor to be put in place for 2019, and therefore they are “in limbo.”
- “Should employers continue with current programs, considering the risk of EEOC enforcement or private legal action, or should affected employers come up with a plan B?”
- Plan B should include “indemnification options” by vendors such as…hmmm…let’s take a looksee at who they recommend…ah! Quizzify.
- Screening doesn’t work anyway, so why do it when it could just create liability absent that indemnification?
There is, they added, some further urgency because “it’s unclear whether safe harbor protection will be removed from 2019 premium differentials based on 2018 screenings, or only based on 2019 screenings and health reimbursement accounts.” In other words, you need to get your screening-alternative plan in place now, or else you may lose the entire premium differential in 2019. (Meaning an employee can obtain the best health plan option even if he/she refuses to be screened in 2018 and you didn’t offer Quizzify as an alternative, to render the screening voluntary.)
Of course, as in every other article about the EEOC rules, it is de rigueur to quote a screening vendor urging employers to keep their heads firmly anchored in the sand. In this case, the quoted vendor is urging employers to “continue to be compliant with the existing regulatory environment and monitor developments.” (At least this is better than Bravo, which accused us of spreading “rumors, chatter and fiction” about the 2018 sunsetting. Our crime? The same as usual in wellness: we were honest and accurate, two adjectives that could never be applied to most wellness vendors.)
The problem with this quoted vendor’s sentiment? There are no “developments” left to “monitor.” The EEOC has already said what it intends to do to preserve the employer safe harbor in 2019 (nothing), leaving employers who want a safe harbor no alternative other than to seek indemnification, such as Quizzify’s.
Therefore, regardless of what screening vendors want you to do (which is more screening, surprisingly), learn what is certain to happen in 2019. Otherwise you’re flying blind. And in the immortal words once again of Yogi Berra, if you don’t know where you’re going, you’ll end up someplace else.
The announcement of Dr. Atul Gawande as the head of this joint venture means they’ll be ending their pry, poke and prod programs — and instead focus on exactly the type of thing Quizzify does. Here is Dr. Gawande’s exact quote:
Virtually every family in the country, the research indicates, has been subject to overtesting and overtreatment in one form or another. The costs appear to take thousands of dollars out of the paychecks of every household each year…Millions of people are receiving drugs that aren’t helping them, operations that aren’t going to make them better, and scans and tests that do nothing beneficial for them, and often cause harm.
in other words, the biggest problem among the workforce is a health literacy deficit, not a broccoli deficit. If there is one thing health literacy courses teach, it’s this: Just because it’s healthcare doesn’t mean it’s good for you.
Note that this personal blog post does not necessarily represent the views of any organization with which I am affiliated, other than the one with which I co-founded. I am referring, of course, to the Needham Frisbee Club, where everyone is welcome to join and play and become fitter — since fitness at any size, not corporate crash-dieting contests, is the key to health.
By now, many facts are well-known about weight and weight loss programs:
- Variations in body size do not correlate with variations in willpower
- No one really knows why the country has gotten fatter since 1986, reversing the trend through 1985, and without understanding the causes of this fairly sudden reversal, it’s not possible to address it. (We do know that the lowering of cutoffs in 1989 created an additional 30 million “overweight” people in the U.S. overnight. http://www.cnn.com/HEALTH/9806/17/weight.guidelines/)
- It is much better to be “fit and fat” than to try to diet your way to health
- The vast majority of people who lose weight gain it back
- 1/3 to 2/3 gain back more than they lose
- No wellness vendor has discovered the secret to weight loss that has eluded researchers for decades
- The often quoted 90-95% failure rate of programs is likely underestimated.
Further, while perhaps not proven, there is growing evidence, also here, and here, that weight cycling may be hazardous to health. (This would likely be particularly true when an employer ties incentives to gaining weight for the first weigh-in in order to lose it by the second weigh-in.)
And, yet, a number of the workplace wellness industry’s very stable geniuses have chosen to body-shame employees. The individuals and companies listed below are the wellness industry’s leading body-shamers, charter members of the Body-Shaming Hall of Shame. No surprise that wellness luminaries are leading the charge towards body-shaming, as their industry has repeatedly been called words like “sham” and “scam” by Pulitzer Prize-winning media outlets not otherwise known for name-calling.
Where possible, we have provided contact information, that you can use to let the appropriate people know how you feel about endorsing body-shaming in the workplace. Obviously, one can never eliminate discrimination based on body type, but hopefully this exposé, and creating the Body Shaming Hall of Fame, will reverse the trend towards employer support of weight discrimination in wellness programs.
Troy Adams, Wellsteps
Wellsteps is known in general for harming employees, and won a Deplorables Award in 2016 for harassing Boise School District employees. Mr. Adams cemented his and Wellsteps’ candidacy for this list by declaring: “It’s fun to get fat. It’s fun to be lazy.” After receiving many complaints, he took that article down. But he never apologized and Wellsteps continues to pitch “wellness or else” programs in which employees are fined if they can’t lose weight.
Ignorance of physiology (fines and incentives have never cured any disease known to mankind) is quite consistent with the rest of Wellsteps’ philosophy. They also have no understanding of arithmetic (costs can’t increase and decrease at the same time), drinking (it is OK to have wine with dinner or a beer at a ballgame), smoking (smokers don’t take their first steps to quitting by smoking only on weekdays), nutrition (“one more bite of a banana” will not improve your health), and arithmetic again.
You can let Wellsteps’ largest client know how you feel about this by writing to the Boise School Committee at Jeannette.firstname.lastname@example.org and copying the editor of the local newspaper, Rhonda Prast, at email@example.com.
Michael O’Donnell, American Journal of Health Promotion
Michael O’Donnell served, until recently, as the prevaricator-in-chief of the industry trade publication, the American Journal of Health Promotion, which might as well be called the American Journal of Self- Promotion, for the simple reason that – despite the overwhelmingly poor economics of “pry, poke and prod” programs and their strong likelihood of harming employees – they have published only one single sentence critical of wellness…and when that was discovered to have slipped through pre-publication review by their thought police, they walked it back in the next issue.
Mr. O’Donnell was voted into the Hall of Shame thanks to his proposal to charge employees for insurance based on BMIs, a “pay what you weigh” approach, like ordering lobsters or sending a package.
- Prospective new hires should be subjected to an intrusive physical exam and hired only if they are in good shape. OK, not every single prospective new hire — only those applying for “blue collar jobs or jobs that require excessive walking, standing, or even sitting.” Hence, he would waive the physical exam requirement for mattress-tester, prostitute, or outcomes analyst for a wellness company – because those jobs require only excessive lying.
- Employees above his ideal weight would pay per pound.
- He would “set the standard for BMI at the level where medical costs are lowest.” Since people with very low BMIs incur higher costs than people with middling BMIs, Mr. O’Donnell would fine not only people who weigh more than his ideal, but also employees with anorexia.
If employees didn’t already have an eating disorder, what better way of giving them one — and hence extracting more penalties from them — than to levy fines based on their weight?
We aren’t making this up. Here is an excerpt:
He claims that all these weigh-ins and fines will create an “insanely great program” for employees, whether they like it or not.
Vitality Group, Johnson & Johnson – and Ron Goetzel
Where would a wellness-related Hall of Shame be without Ron Goetzel? Name a debacle or scandal in wellness, and his fingerprints are on it. Penn State, Nebraska, McKesson, Bravo/Graco, and of course Wellsteps come immediately to mind.
He was also the very stable genius behind the Johnson & Johnson Fat Tax. The Fat Tax was supposed to be a game-changer, ostracizing overweight folks with the misfortune of working for publicly traded corporations. In this scheme, companies would weigh their employees and then disclose those weights to shareholders. The shareholders would presumably reward those companies doing the best job of reducing employee weight, creating more profit for the wellness vendors, like Vitality or Johnson & Johnson, who would help employees lose weight. Ultimately it would be a tax, in that every employer that did not hire a wellness company and/or fire fat employees would see its stock price tumble, making wellness a mandatory fee.
While this “fat tax” would go a long way towards achieving the Wellness Ignorati’s goal of monetizing body-shaming, bringing financial disclosure into the picture raises all sorts of regulatory issues. Could you force employees to be weighed in order to meet SEC disclosure rules? What if employees cheated on the weigh-in, as employees are wont to do? Would that create a Sarbanes-Oxley violation?
There are three ironies here. It turns out that companies that are obsessed with prying, poking and prodding their employees, like McKesson, watch their stock prices tumble. And companies specifically obsessed with goading their employees into crash-dieting contests, like Schlumberger’s chart below, have the worst stock performance of all.
Second, it turns out that Vitality can’t get its own employees to lose weight, and yet they want you to hire them to get your employees to lose weight.
Finally – and this shouldn’t come as a surprise to anyone – there is zero correlation between employee weight and corporate performance.
Mr. Goetzel works for Johns Hopkins and often places their name on his essays. If you have an opinion on whether Johns Hopkins should be supporting institutionalized body-shaming, you can express your opinion by writing to Dean Ellen MacKenzie at firstname.lastname@example.org .
Dr. Delos “Toby” Cosgrove, president of the Cleveland Clinic. After commenting that he would not hire smokers at the Clinic, he added that he would not hire obese people if he could legally deny them jobs.
So he doesn’t want to work with obese people, except if they happen to be president.
Dr. David Katz coined the term “oblivobesity” because apparently, he feels we have not yet made larger people feel bad enough about themselves to force them to do something about their weight – the difficulty of which has apparently been overstated because, according to Katz writing in the Huffington Post:
“There are rare cases of extreme weight loss resistance and such, but by and large, we can lose weight and find health by eating well and being active. Really.”
He deftly rebuts 30-plus years of consistent and conclusive research to the contrary by adding “really” to the end. Because everyone knows that makes a statement true. Really.
He also continues to illustrate his postings with pictures of headless fat people. And then there is his defense of Dr. Oz.
Please feel free to contact us about additional “shamers” you would like to add to the list along with the reasons why.
If there is one thing the US healthcare system is really really good at, it’s rooting out hidden disease via massive hyperdiagnostic screening campaigns. But there is always room for “improvement” by finding some unsuspecting cohort — in this case, 45-year-olds — that was getting just a little too complacent about the fact that virtually no one that age dies of something that could have been found — and also prevented or addressed — via a non-USPSTF-recommended screen.
Serves them right.
The American Cancer Society (ACS) recently decided that, because the rate of colon cancer has been increasing in the 45-to-49-year old cohort, that screenings should start in that age group. The “alarming” 22% increase in relative risk during this century translates into an increase in the absolute rate of colon cancer in the <50 cohort from 0.006% to 0.007%. Yes–0.001% more of the <50 population in this country will get colon cancer now than 18 years ago. I’m surprised they didn’t recommend calling out the National Guard.
Further, many of that 0.007% experienced symptoms, and hence would be getting a colonoscopy as a diagnostic test, not a screen. And others in that age grouping had a family history and should get screened regardless of what the “average” person should do. Suppose those two categories account for half of the colon cancer population. That leaves roughly 0.0035% of the 45-to-49-year-old population who could possibly benefit from a screen.
As with the other “alarming” colon cancer figures that have been published in the last few years, your chances of having your life saved by a colon cancer screening at that age is about the same as your chances of being struck by lightning.
And a screen is far from a lifesaver in general. Quite the contrary, statistically speaking it is likely to find the slow-growing tumors while missing the more aggressive, faster-growing tumors that begin between screens.
The Hazards of Screening
That trivial benefit must be weighed against the nontrivial harms. The risk of a complication, such as a perforation, is estimated between 1.6% and 1.8%. (In all fairness to the ACS, they aren’t insisting that the screen be done via a colonoscopy, though the non-invasive screens have such high positive/inconclusive test rates that they often lead to colonoscopies.)
Unless I have the decimal point in the wrong place, that means the rate of complications is a whopping 320 times the likelihood of something being found. Oh, wait a sec — make that 3200 times.
OF course, the worst complication is death, and the mortality rate from colonoscopies (0.02%) appears to be, on its face, much higher than the rate of lives that would be saved. However, once again, though it kills me to say it, in all fairness the mortality rate, and for that matter the complication rate, increases with advancing age, meaning the younger you are, the less likely you are to die from this screening. So maybe the mortality rate in the 45-50-year-old cohort isn’t any higher than — and might even be slightly lower than — the rate at which early detection will save lives. I feel much better knowing this. Don’t you?
And what is it about colon cancer that brings out people’s inner very stable genius? Here is the Cleveland Clinic on the subject:
Newsflash: 144,000 is not “1 out of 19 people in the United States.” It is barely 1 out of 19 people in greater Cleveland.
The best argument against screening 45-year-olds
Nonetheless, when it comes to screening 45-year-olds for colon cancer, the best argument against it is that Star Wellness is for it. By way of background, Star Wellness is best known in wellness for not knowing anything about wellness. They take great pride in that, boasting that anyone can become a wellness vendor. All you need, they say, is a background in “sales or municipality administration,” five days of training…and of course a certified $65,000 check payable to — get ready — Star Wellness. No surprise that Star was leading the wellness industry’s race to the bottom until they got outstupided by Total Wellness, Interactive Health, and Wellsteps.
But Star Wellness is not willing to lose this race to the bottom without a fight.
Not content to offer the full range of USPSTF non-recommended screens, they are practically hyperventilating over this opportunity to add yet another one. They use the example of ovarian cancer screening to justify more colon screening. Here is the USPSTF on the subject of ovarian cancer screening:
The USPSTF found adequate evidence that screening for ovarian cancer can result in important harms, including many false-positive results, which can lead to unnecessary surgical interventions in women who do not have cancer. Depending on the type of screening test used, the magnitude of harm ranges from moderate to substantial and reflects the risk for unnecessary diagnostic surgery.
While we’re on the subject of Star Wellness…
Star, Vitamin B12 is not a vaccine.
And remind me why we are lining up employees to get Vitamin B-12 shots, vaccines or no vaccines?
While we’re on the subject of vaccines, according to the CDC, the biggest category of people who are supposed to get Hepatitis A/B vaccines include street drug users. If you are routinely hiring enough street drug users to be holding vaccination clinics focused on Hepatitis A/B, I’d say Vitamin B-12 deficiencies are not your biggest problem.
Rarely can you become an expert in something in 3 minutes but then again rarely is there a wellness vendor as cool as Wellable. Their 3-minute “Whiteboard Wednesday Wellness Minute” will show you how to make lemonade out of this EEOC lemon.
Note that this blog post is my personal posting and does not necessarily represent the views of any organization with which I am affiliated, other than the one with which I am most closely associated, and of which I am one of the founders. I am referring, as everybody knows, to the Needham Frisbee Club. People who play Ultimate 3 times a week don’t need no stinkin’ checkups.
Why Wellness Vendors Hate Information: A New Theory
I have no clue why wellness vendors hate information so much. Perhaps they are repressing childhood memories of being bitten by a librarian.
A far-fetched theory, perhaps, but there is simply no other explanation for half the things half these very stable geniuses insist upon doing. In many cases, reams of information demonstrating the futility, fallacies and even harms of what they do is right there — begging to be googled — and yet no one in the wellness industry (or at least the wellness companies “profiled” on this site — there are plenty of exceptions listed at www.ethicalwellness.org) does.
Before we get into the checkups, consider some other information gaps, like the eight-glasses-of-water urban legend. Anyone with an internet connection can easily learn that you do not have to drink eight glasses of water a day, and the whole meme was completely made up. 70 years ago someone estimated that humans require that much water a day — but also that basically everyone with access to water already gets that much without having to force themselves to drink when they aren’t thirsty.
Yet try telling that to a wellness vendor (excluding the ones who have signed the Code of Conduct, of course). One vendor, Provant, even provides an infographic in case the employees they are harassing can’t count to eight:
Wellness Corporate Solutions — no stranger to these pages — has gone one step farther. Along with their crash-dieting contests, they offer what they call “healthy competitions” to see who can drink the most water:
Water-drinking “healthy competitions” may or may not make employees “more aware of their health status,” but they certainly make employees “more aware that this meeting better end really soon.”
Maybe WCS should combine those two competitions — along with their massive overscreening campaigns — to create a competition to reward employees for doing the most stupid things to themselves.
Failure to understand that thirst is your brain’s signal that you need a drink of water is not an isolated oversight. Wellness vendors take great pride in their ignorance of wellness generally. Consider their propensity to screen the stuffing out of employees. There are clinical guidelines for optimal screening frequencies and lists of biometrics that should be screened for, that most wellness vendors (It Starts with Me and Limeade being two huge exceptions) have apparently never laid eyes on. If it helps, here they are:
There are a few subtleties beyond these words. “People at risk for diabetes” (under “Diabetes test”) would include people with high blood pressure or family history (which wellness vendors can’t ask about). It would also include people who are overweight or obese. Additionally, “members of certain ethnic/racial groups may be at increased risk at a lower body mass or a younger age.” Otherwise, it’s quite clear that cardio screenings should begin at 35 for males and 45 for females, and take place “at least once every five years” after that.
Some people should get that frequency, others a higher one. But like most other things in healthcare, the answer is not the same for every employee of every age and every health status, and you do not just screen people because you make money on each screen, so the more you screen, the more you make. Otherwise you end up like Interactive Health, one of the most expensive vendors, positively hyperventilating about all the false positives they’ve found:
Finally, let’s once again review the aforementioned crash-dieting contests, a staple of many wellness programs besides Wellness Corporate Solutions. Schlumberger, for example, pays out thousands of dollars to the team which does the best job packing on the pounds in December and then taking them off in January. “Just plain fun,” is how their ironically named vendor, HealthyWages, describes it. None of these vendors have apparently seen the CDC’s advisory memo warning that crash-dieting is futile, likely counter-productive, and possibly harmful.
What about annual checkups?
Let’s cut to the chase: there is not one shred of evidence that annual checkups are a good idea for asymptomatic working-age employees. There are many good reasons to go to the doctor — you notice a change in some aspect of your body, you want to develop a plan to improve your health, you need help managing a chronic disease, or even that you’re sick — but here’s what’s not among them: the earth completing a revolution of the sun.
New England Journal of Medicine says that while the major benefit is “less patient worry,” checkups “may actually be harmful.”
“Less worry” is not necessarily a good thing. An employee (name on request after an NDA — not a made-up person) had a checkup in order to collect a wellness incentive…and as a result of being told not to worry, ignored heart attack symptoms about a week later.
The Journal of the American Medical Association says offers of health checks did not reduce any kind of mortality, but “may be associated with more diagnoses and drug treatments.”
Choosing Wisely says: “Annual checkups usually don’t make you healthier,” and “tests and screenings can cause problems.”
None of this takes into account the cost of annual checkups — which often lead to more unneeded and expensive tests and prescriptions, as JAMA notes — but we have definitely observed that wellness vendors and even some HR departments don’t really care about costs. It’s not their money. Here is Reuters on the high and unneeded cost of prevention.
Meanwhile, I’ve yet to find a wellness program that does not either pay employees to get checkups or fine them if they don’t — or shunt them into a worse health plan unless they submit to an annual physical.
I would also note that, however useless annual checkups are to begin with, they are likely even more useless if someone is visiting the doctor because their benefits department is forcing them to do so, against their will.
Finally, there isn’t exactly a surplus of primary care doctors. Why are we paying healthy employees to take up clinician time that unhealthy employees might actually need?
What is the argument in favor of checkups?
If checkups don’t actually prevent anything, why make employees undergo them? Two reasons have been proposed. One is that employees can “build a relationship” with their PCP. This of course assumes that neither the employee nor the PCP ever retires, moves or changes jobs. It also assumes that somehow the things that affect employees can be prevented by having a “relationship” with a PCP. However, if you look at the list of the most frequent reasons for hospitalization among the working-age population, it’s kinda hard to find anything that fits that description.
Can you think of any disease in your own life that would be cured by a relationship with a PCP? I can’t think of only one problem — chronic heartburn — that my PCP could have prevented. But she didn’t. The PCP was perfectly happy to keep me on Prevacid, which, as Quizzify teaches (right on the home page quiz!), is likely harmful in long-term use. Fortunately, I happened to run into a yogurt salesman one day, who told me about active-culture yogurt. Within days my heartburn was gone, never to return.
The second argument in favor of checkups, proposed by the CEO of Bravo Wellness, Jim Pshock, is as follows:
The hope is that the [Bravo] program will get people to proactively see their physicians to manage their health risks. Yes, this will, hopefully, mean more prescription drug utilization and office visits, but fewer heart attacks and cancers and strokes.
It isn’t his money, so he is perfectly fine with employees “hopefully” spending more on drugs and office visits. On the other hand, there is no information supporting his claim that all this spending and all these checkups will prevent all these diseases. Quite the contrary, 100% of available information reaches the opposite conclusion — especially JAMA, which specifically measured mortality due to heart attacks, cancers and strokes and found no improvement. You’ll fine zero information suggesting the contrary finding, no matter how hard you search.
Perhaps when he was a toddler, Mr. Pshock’s parents threw him into an entire cage of librarians.
What is the best frequency for checkups?
The literature is quite adamant: not at all. That seems a bit extreme and I would bet the people who write these articles do occasionally get a checkup. For the most reasonable compromise I would turn to Quizzify, the leading health literacy vendor. They recommend a simple mnemonic: get two checkups in your 20s, 3 in your 30s, 4 in your 40s, 5 in your 50s, and annually after that. Quizzify’s advisory colleagues, doctors at Harvard Medical School, approved this recommendation too. As with most other questions, this one carries the HMS “shield.” (Quizzify also reports that this question is the one most likely to be removed by its customers, which is an option for all questions in their database before they get seen by employees.)
So what’s the solution?
In three parts, it’s:
- Screen according to guidelines
- Send employees to the doctor at age-appropriate and health-appropriate intervals
- Pay the fines on overdue books.
Sometimes we bring up the many ways in which conventional outcomes-based “pry, poke and prod” wellness programs harm employees. For the first time, we are putting all those harms in one place, a hand clip-and-save guide for journalists, regulators, and legislators.
This series now includes three. First is The Outcomes, Economics and Ethics of the Workplace Wellness Industry. The good news about this one is its exhaustive comprehensiveness in covering the industry’s misdeeds, garnished with 400 linkable footnotes. The bad news is it was published more than 9 months ago, too soon to capture the most recent swarm of misdeeds. For example, it predated Interactive Health’s scorched-earth screening program, designed to leave no employee undiagnosed. (This is literal — according to their own data roughly a quarter of employees discover “new conditions” every year. So in 4 years, every employee, on average, gets one new condition.)
The next was an expose of the economics of wellness, a compelling, fully sourced and linked proof that the whole pry, poke and prod endeavor served no economic purpose beyond enriching pry, poke, and prod vendors. (Screening according to guidelines, should a vendor ever choose to do it even though it would require sacrificing two-thirds of revenues in the name of integrity, would be exempted from this conclusion.) That’s because there is no chance that vendors “playing doctor” at work saves money.
Confucius observed that an mistake that remains uncorrected after being pointed out becomes a lie. Using that definition, two-thirds of the wellness industry –– including the Koop Award Committee and the Health Enhancement Research Organization — is lying, as they are fully aware that their very stable economic genius fantasies are nothing more than the stuff dreams are made of. That also explains why the $3 million reward for showing wellness is not an epic fail remains unclaimed.
The Hazards of Workplace Wellness
This whole thing would be hilarious were it not for all the harms and hazards of workplace wellness visited on employees who are forced to choose between, as Judge Bates noted in his epic decision in AARP v. EEOC, paying two months’ rent or forfeiting that sum by submitting to needles wielded by unlicensed, unregulated and unsupervised wellness vendors. Employees should never be forced into clearly unhealthy situations at work, at least without the hazards being disclosed, and yet, today’s American Journal of Managed Care posting covers six hazards employees face as they navigate the shoals of workplace wellness:
- Actual, well-documented, harms to an exposed population
- First-person case studies and reports
- Crash-dieting-for-money risks
- Flouting of established clinical guidelines
- “Hyperdiagnosis” leading to unneeded medical care
- Incorrect or potentially harmful advice that employees are told to take
Not if you don’t have a license, aren’t required to understand what you are doing, and can force employees to harm themselves or lose money