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The first post in this three-part conclusion to our analysis of the HERO report is here.
Part Two: How to Do WSME plausibility-testing
This is the installment where we actually offer useful guidance.
All the tools and guidance are available from our site (for a fee in some cases — but no fee for employers requesting this information for their own populations) but here is the simple process (minus a few asterisks):
- Make a list of the key ICD-9 codes. Since you would do smoking cessation with or without a wellness program, we recommend taking out COPD and chronic bronchitis. Likewise, if you’re trying to save money, take out asthma, where the “number needed to treat” and the cost of medications means spending about $10 to save $1.00 in ER and inpatient expense.
- Count the number of events in the codes. We use an Excel sheet to tally them, as seen here. We combine ER and IP for tallying event rates for various reasons, but separate them out when calculating savings. Be sure not to double-count ER visits leading to admits, professional fees billed separately etc.
- Apply your covered population (total covered person-months times 12) to create a rate per 1000.
- Do it for several years going back to discern a trend and – if you don’t use our database – get together with some of your counterparts at other similar organizations to create a benchmark.
You should end up with a result that looks like this one though likely not as steep, from Providence Health Plan’s award from the Validation Institute.
Where the HERO write-up is wrong is suggesting that this event-rate methodology be used to check other methodologies. Sure, but if this methodology shows no noticeable event reduction and another methodology “shows savings,” which one is wrong? So why use the other methodologies at all if indeed you’re just going to have to keep paying your consultants to redo them to match this one?
Calculating Savings and ROI
Both savings and ROI are remarkably easy to calculate. For savings, just take a “standard cost” for each event and multiply it by the number of events that you believe to have been “avoided.”
For ROI just divide that savings figure by the cost of the program (inclusive of all the costs to run it including all vendor fees and incentives).
Cautions for WSMEs
First, because there are so few WSMEs to tally (as noted in the government reports analyzed in the first installment), you need a largish population to identify enough of them to discern a consistent trend. Otherwise there will be a lot of “bouncing.” Two ways that smaller populations can smooth the bouncing are:
- Look at the total number of events rather than try to track individual events, and
- Combine multiple years in both baseline and intervention periods. So if you started in 2013, compare 2013+2014 to 2011+2012, rather than, or in addition to, drawing a graph like Providence’s above.
Second, even if you get a decline, you still need to check that decline against improvements in compliance or risk, to make sure that the decline in WSMEs was not due to good fortune but rather to a significant improvement in workforce health. (Also, consider workforce “disruptions.” Did your company merge with another? Offer early retirement packages or buy-outs, etc?) This is a very important check-and-balance because the wellness industry is notorious for attributing tremendous declines in cost to small improvements in risk factors or compliance. (Those programs usually win Koop Awards.)
Third, you need to compare to national averages. (We can do this for you but you can also puzzle this out from government data, if you have the time or expertise.) As a group, the national average benchmark cardiometablic WSME rate tends to be stable except for cardiac events, which have been falling dramatically for years. In the <65 population, cardiac events are no longer common. Heart attacks themselves are 1-in-800 shots in the <65 population. (That low rate raises the much more basic question of why anyone would do “pry, poke, prod and punish” wellness in the first place, because HERO now agrees with us that wellness loses money.)
Hence, if you read Installment #4 of this series, you’ll see that HERO is claiming the WSME methodology shows savings in cardiac events…but they forgot to adjust for the benchmark decline. That adjustment wipes out all their savings.
Fourth, don’t double-count. You can only measure WSMEs against the combined spending for wellness and disease management. Anyone who tells you that you can measure each intervention separately is wrong. If your event rates fall, was it due to a small intervention on a large number of people (wellness) or a focused intervention on a small number of people (disease management)?
Fifth, your consultants will try to talk you out of a WSME analysis, which itself should be reason enough to do it. It will show exactly what the HERO report and government data show – that WSMEs typically represent a trivial amount of your spending, that they don’t decline much except in cardiac (which comes down anyway), and that the savings doesn’t remotely approach the cost of the program.
Plus, this analysis doesn’t cost much — another drawback from the consulting firm’s viewpoint.
Two classic vendor sleight-of-hand tricks
The vendor (and probably your consultants, especially if they “selected” the vendor, a la Staywell and Mercer) will try to wriggle out of this valid methodology two different ways. First, they will say this analysis should only be done on participants. That, of course, is exactly the wrong answer. Participants always show savings. The whole point of a plausibility test is to see if the event rate decline among participants was simply self-selection and regression to the mean, or whether it was real. If the latter, the real improvement amongst participants will drive the entire WSME rate down.
Second, they will want to “adjust” for the increase in prevalence. Do not allow this (unless you significantly changed your workforce demographics). “Prevalence” doesn’t mean anything. If you look hard enough, you can “find” people with disease. For instance, the Koop Award-winning Nebraska state program vendor “found” 40% of state employees were at high risk. Only 3% of them subsequently went on drugs, and only 3% reduced their risk factors…and yet somehow a huge amount of money was saved.
And the database to which you compare your rates doesn’t “adjust” for rising prevalence either, so the comparison is valid. The rate is the rate, period.
What happens when you use this methodology
You may show some very modest savings, like the textbook example on Page 23 of the HERO guidelines shows – 99 cents PMPM.
HERO admits this doesn’t cover the $1.50 of vendor fees noted on Page 15, let alone all the other costs of wellness.
And you can forget about covering the average $693 in incentives with your 99-cents-a-month savings. Even Quizzify, the only population health vendor to guarantee savings, doesn’t claim it can cover incentives too.
There simply aren’t enough WSMEs, and they aren’t sufficiently reducible to generate meaningful savings. Your costs aren’t concentrated in “unhealthy” employees who should be eating more broccoli. Your costs are all over the map. The mantra of our universally acclaimed award-winning outcomes measurement trade bestseller Why Nobody Believes the Numbers:
Everything in life has an 80-20 rule. In healthcare, the 80-20 rule is that 80% of the time, there is no 80-20 rule.
That’s why focusing on one area, even one that’s all the rage, won’t move the needle. And that’s why Quizzify’s “Jeopardy®-meets-health benefit education-meets-Comedy Central” philosophy is to educate employees and change employee behavior on everything, not just broccoli.
In our third and final installment, we’ll give you the chance to download gratis a very user-friendly tool that you can use to do your own analysis of the ROI of your own wellness program.
In the immortal words of the great philosopher Dizzy Dean, don’t fail to miss it.
This is the third in a series deconstructing the Health Enhancement Research Organization’s (HERO) attempt to replace the basic outcomes measurement concepts presented to the human resources community in Why Nobody Believes the Numbers with a crowdsourced consensus version of math. The first installment covered Pages 1 to 10 of their outcomes measurement report, where HERO shockingly admitted wellness hurts morale and corporate reputations. The second installment jumped ahead to page 15, where HERO shockingly admitted wellness loses money. This report covers pages 11-13. Next week we shall be covering Page 14.
Spoiler Alert: The wellness industry believes that math is a popularity contest. (We have a million-dollar reward if they can show that’s true. More on that later.)
All the luminaries in the wellness industry got together to crowdsource arithmetic, and put their consensus (a word they use 50 times) in an 88-page report. Unfortunately, math is not a consensus-based discipline, like democracy. It is not even an evidence-based discipline, like science. It is a proof-based discipline. A methodology that doesn’t work in hypothetical mathematical circumstances is proven wrong no matter how many votes it gets.
The pages in question list 7 “methodologies” for measuring outcomes. To begin with, consider the absurdity of having 7 different ways to measure. Imagine if you asked your stockbroker how much money you made last year, and were told: “Well, that all depends. You could measure that seven different ways. And by the way, six of those ways will overstate your earnings.” Math either works or it doesn’t. There is only one right answer.
Methodology #1: “Cost Trend Compared with Industry Peers”
This methodology “may require consulting expertise.”
As a sidebar, one of the many ironies of this HERO report is that most of these methodologies emphasize the need for actuarial or consulting “inputs” or “analytic expertise”…and yet no mention was made on Page 10 of the cost of this expertise when all the elements of cost were listed. While not mentioned as a cost element, consulting firms are very expensive And even if consulting were free, we generally recommend hiring only consultants to do outcomes report analysis who are certified in Critical Outcomes Report Analysis by the Validation Institute.
By contrast, Staywell and Mercer offer an example of what happens when you as a buyer use non-certified “consulting expertise” to evaluate a vendor. Here’s what happens: the vendor wins. Needless to say, Staywell showing savings 100x greater than what Staywell itself said was possible simply by reducing a few employees’ risks raises a lot of questions. But despite repeated requests and offers of honoraria to answer these questions, Mercer wouldn’t answer and the only response Staywell gave us was to accuse us of bullying them. Staywell and Mercer held firm to the Ignorati strategy of not commenting—even though Mercer was representing the buyer (British Petroleum), not the vendor. Oh, yes—both Staywell and Mercer are represented on the HERO Steering Committee.
To HERO’s credit, they do admit the obvious for Methodology #1: If all your peers are using the same vendors, who recommend the same worthless annual checkups, the same overscreening/overdiagnosis, the same lowfat(!) diets, and the same consultants to evaluate all the phony savings attributable to these checkups, diets, and biggest-loser contests, obviously you’ll get the same results. And since trend is going down everywhere (including Medicare and Medcaid, which have no wellness), everyone gets to “show savings.”
Methodology #2: “Inflection on expected cost trend.”
Mercer has been a big proponent of this methodology, as in the previous Staywell example. At one point they used “projected trend” to find mathematically impossible savings for the state of Georgia’s program even though the FBI(!) later found the program vendor, APS, hadn’t done anything. In North Carolina, they projected a trend that allowed them to show massive savings in the state’s patient-centered medical home largely generated, as luck would have it, by a cohort that wasn’t even eligible for the state’s patient-centered medical home.
Comparing to an “expected” trend is one of the most effective sleight-of-hand techniques in the wellness industry arsenal. Every single published study in a wellness promotional journal comparing results to “expected trend” has found savings. And have you ever hired a consultant or vendor to compare your results to “expected trend” who hasn’t found “savings”? We didn’t think so.
Methodology #3: “Chronic vs. non-chronic cost trend.”
The funny things about this methodology are twofold.
First, the HERO Committee already knows this methodology is invalid because it was disproven in Why Nobody Believes the Numbers (and I offered an unclaimed $10,000 reward for finding a mistake in the proof). We know that people on the Committee have read my book because at least one of them – Ron Goetzel – used to copy selected pages from it until the publisher, John Wiley & Sons, made him stop. Methodology #3 was the fallacy on which the entire disease management industry was based. I myself made a lot of money measuring outcomes this way, until I myself proved I was wrong. At that point, integrity being more important to me than money, I changed course abruptly, as memorably captured by Vince Kuraitis’ headline: Founding Father of Disease Management Astonishingly Declares: “My Kid Is Ugly“. (Naturally the benefits consulting industry filled the vacuum created by my withdrawal from this market, and plied their clients with worthless outsourced programs that more than coincidentally generated a lot of consulting fees.)
If you had perfect information and knew who had chronic disease (before the employees themselves did) and everyone stayed put in either the non-chronic or chronic categories, you could indeed use non-chronic trend as a benchmark, mathematically (though the epidemiology is still very squirrelly). The numbers would add up, at least in a hypothetical case.
But we can’t identify anywhere near 100% of the employees who have chronic disease. Absent that perfect information, any fifth grader could understand the proof that this methodology is fabricated, as follows. Assume that 10 people with a chronic disease cost $10,000 apiece both in the baseline and in the study period. Their costs are therefore flat. The program did not reduce costs between periods.
Now add in 10 people with undetected chronic disease as the “non-chronic benchmark.” Maybe they are ignoring their disease, maybe they don’t know they have it, maybe they are misdiagnosed, maybe the screen was wrong (vendor finger-pricks are very unreliable). Assume these 10 people cost $5000 in the baseline…but they have events in the study period so their costs become $10,000.
That makes the “non-chronic trend” 100%! Suddenly, the program vendor looks much better because they kept the costs of the chronically ill cohort constant even though the “benchmark” inflation was 100%.
Second, Why Nobody Believes the Numbers has already shown how to make this methodology valid mathematically (though the epidemiology applied to that math might still be squirrelly, and there could still be random error in non-hypothetical populations). You simply apply a “dummy year analysis” to the above example. So do exactly what is described above, but for a year-pairing before the program. Then you’ll know what the regression-to-the-mean bias is, and apply that bias to the study years. So If in fact the “non-chronic trend” is always 100% due to the people with unrecognized chronic disease, you would take this trend out of the benchmark non-chronic population before applying that trend to the chronic population. In this case, as in every case, the bias is eliminated. This is called the Dummy Year Adjustment. (Chapter 1 of Why Nobody Believes the Numbers offers several examples of the DYA.)
Proofs are best understood to be proofs if accompanied by rewards, since only an idiot would monetarily back a proof that wasn’t a proof. So here’s what we propose for this one: I’ll up my $10,000 reward to $1,000,000. A panel of Harvard mathematicians can decide who is mathematically right. The HERO Committee escrows a $100,000 nuisance fee for wasting my time and paying for the panel if they are wrong. (We’ll pay if we lose.) They present Methodology #3. We lose the $1,000,000 if the panel votes that this HERO methodology is valid without our “Dummy Year Adjustment.”
My challenge: Either collect your $1,000,000, or publicly apologize for proposing a methodology which you know to be made up. Or is offering you a million dollars “bullying,” a word defined very non-traditionally in this field? Our bad.
Yes, we know this sounds like a big risk but you might remember the old joke:
Science teacher: “If I drop this silver dollar into this vat of acid, will it dissolve?”
Student: “No, because if it would, you wouldn’t do it.”
Methodologies 4 and 5: The Comparison of Participants to Non-Participants
Besides not making any intuitive sense that active motivated engaged participants are somehow equivalent to inactive unmotivated non-participants, Ron Goetzel already admitted this methodology is invalid. Health Fitness Corporation, accidentally proved that on the slide below.
Note that they “matched” the participant (blue) and reference (red) groups in the 2004 “baseline year” but didn’t start the “treatment” until 2006. However, in 2005, they already achieved 9% savings vs. the “reference group” even without a program. This “mistake” was in plain view, and was pointed out to them many times, politely at first. Page 85 of Why Nobody Believes the Numbers showed it, but as the screenshot below shows, I was too polite to mention names or even to call it a lie, figuring that as soon as Health Fitness Corporation or Ron Goetzel saw it, they/he would be honest enough to withdraw it.
Not knowing the players well, I naively attributed the fact that HFC used this display to a rookie mistake, rather than dishonesty. That was plausible because rookie mistakes are the rule rather than the exception in this field. (As we say in Surviving Workplace Wellness, the good news about wellness vendors is that NASA employees don’t need to worry about their job security because these people aren’t rocket scientists.)
On the advice of colleagues more familiar with the integrity of the wellness industry true believers, I also tried a test of the rookie-mistake hypothesis: I strategically placed the page with this display next to the page that I knew Ron Goetzel would be reading (and copying), a page whereon I complimented him on his abilities. I might the the world’s only bully who publicly compliments his victims and offers to pay them money:
That way, I would know that if Mr. Goetzel and his Koop Committee and their sponsors HFC didn’t remove this display, it was due to a deliberate intentiion to mislead people, not an oversight or rookie mistake.
Sure enough, that display continued to be used for years. Finally, a few months ago, faced with the bright light of being “bullied” in Health Affairs, HFC withdrew the slide. Ron “the Pretzel” Goetzel earned his moniker, twisting and turning his way around how to spin the fact that this “mistake” was ignored for so long despite all the times it had been pointed out. He ending up declaring the slide “was unfortunately mislabeled.” He gave no hint as to who did the unfortunate mislabeling, despite being repeatedly asked. We suspect the North Koreans. The whole story is here.
Summary and Next Steps
The first five of these methodologies in Pages 13-14 have several things in common:
- They all contradict the 6th methodology;
- They contradict the statement on page 15 that the only significant savings is in reducing admissions. Of course, self-contradiction is embedded in Wellness Ignorati DNA. To paraphrase the immortal words of the great philosopher Ned Flanders, the Wellness Ignorati “believe all the stuff in wellness is true. Even the stuff that contradicts the other stuff.”
- They call for megadoses of consulting and analytic expertise, contradicting the list on Page 10 that omits the cost of outside expertise.
Speaking of Methodology #6, our next installment will cover it. It’s called event-rate based plausibiltiy testing. I would know a little something about that methodology, since I invented it. I am flattered that the Wellness Ignorati, seven years later, are finally embracing it. I am even more flattered that they aren’t attributing authorship to me. No surprise. That’s how the Wellness Ignorati got their name – by ignoring inconvenient facts. Ignoring facts means they cross their fingers that their customers don’t have internet access. Customers who do can simply google on “plausibiltiy test” and “disease management” and see whose name pops up.
Wellness programs that actually help people improve their health are a good thing. But privacy and protecting workers from job-based discrimination are good things too. Corporations and politicians should take care not to invoke ‘wellness’ in ways that weaken important civil rights protections and give employers license to snoop around in our medical records and our private lives. That would most definitely be bad for our health.
(March 14) This is the first in a series looking at the strengths and weaknesses of the HERO Outcomes Guidelines report, recently released by the Wellness Ignorati. One explanatory note: A comment accused us of insulting the Wellness Ignorati by calling them that. It is not an insult. It describes their brilliant strategy of ignoring facts and encouraging their supporters to do the same. We are very impressed by the disclipline with which they have executed this strategy, and will be providing many examples. However, if they prefer a different moniker to describe their strategy, they should just let us know.
We encourage everyone to pick up a copy of this report, the magnum opus of the Wellness Ignorati. Unlike the Ignorati, we are huge advocates of transparency and debate (which they call “bullying”). We want employers to see both sides and decide for themselves what makes sense, rather than spoon-feed them selected misinformation and pretend facts don’t exist.
The latter is the strategy of the Wellness Ignorati. Indeed, they earned their moniker by making the decision to consistently ignore inconvenient facts. (This is actually a smart move on their part, given that basically every fact about wellness is inconvenient for them.) For example, they just wrote 87 pages on wellness outcomes measurement without admitting our existence, even though we wrote the only book — an award-winning trade best-seller — on wellness outcomes measurement. Observing the blatant suppression of facts and the loss of credibility that comes with blatantly suppressing facts is just one of the many reasons to read this report. In total, their report provides a far more compelling argument against pry, poke, prod and punish programs than we ourselves have ever made, simply by bungling the (admittedly impossible) argument in favor of them.
There is too much fodder for us to deconstruct in one posting, so over the next several weeks we will highlight aspects of this report that we think are especially revealing about the sorry state of the wellness industry.
In terms of getting off to a good start, the Ignorati are right up there with Hillary Clinton, with their first self-immolation appearing on Page 10. Remember our mantra from Surviving Workplace Wellness: In wellness, you don’t have to challenge the data to invalidate it. You merely have to read the data. It will invalidate itself.
And sure enough…
Ironically, the first self-immolation is the direct result of that rarest of qualities among the Ignorati: integrity. We were shocked by the revelation that the Ignorati actually realize that employee morale and a company’s reputation both suffer when companies institute wellness programs – but here is the screenshot. Both morale and reputation are listed, as “tangential costs.”
Try telling a CEO that the morale of his workforce and his corporate reputation are “tangential” to his business. We ourselves run a company, and we would not list low morale as a “tangential cost.” Quite the opposite — our entire business depends on our employees’ intrinsic motivation to do the best job they can. If their morale suffers, our profit suffers. That’s why we would never institute a wellness program. The last thing we want to do is impact our morale in order to measure our employees’ body fat. Obviously, it is harder to hire and retain people if you value body fat measurement over job performance, and we are pleased to see the ignorati finally admit this.
Why, having now read this revelation in the ignoratis’ own words, that wellness is bad for morale, would any company still want to “do wellness”? Or as we say in Cracking Health Costs, “If you’re a general, would you rather have troops with high morale or troops with low cholesterol?”
The fact that employees hate wellness isn’t exactly a news flash. Anytime there is an article in the lay press, the public rails against wellness — or “bullies” the wellness industry, to use the term that the Ignorati use for people who disagree with them publicly. You don’t have to look far—just back to HuffPost on Wednesday. Or All Things Considered.
Obviously, if you have to bribe employees to do something (or fine them if they don’t), it’s because they don’t like it. If employees would rather sacrifice considerable sums of money than be pried, poked and prodded, they are sending you a message: “This is a stupid idea we want nothing to do with.”
The news flash is that this whole business of “making employees happy whether they like it or not,” as we say in Surviving Workplace Wellness is now acknowledged – by the Ignorati as a group — to be a charade.
HERO seems to have exhausted their integrity quota pretty quickly, because after that welcome and long-overdue and delightfully shocking admission, they slip back into character.
Specifically, in their listing of costs, they conveniently forgot a bunch of direct, indirect and “tangential” costs. Like consulting fees. Generally, the less competent and/or honest the consultants, the more they charge. (For instance, we can run an RFP for $40,000 or less, and measure outcomes for $15,000 or less — and do both to the standards of the esteemed and independent GE-Intel Validation Institute. Most other consultants can’t match either the price or the outcome.) We’re not calling any consulting firm incompetent or dishonest other than pointing to a few examples that speak for themselves, but it does seem more than coincidental that the consultants involved in this report have conveniently forgotten to include their own fees as a cost.
And what about the costs of overdiagnosis caused by overscreening far in excess of US Preventive Services Task Force guidelines? The cost of going to the doctor when you aren’t sick, against the overwhelming advice of the research community?
Still, we need to give credit where credit is due, so we must thank the Ignorati for acknowledging that wellness harms morale. It took even less time for this acknowledgement than for the tobacco companies to admit that smoking causes cancer.
Patients overestimate benefits, underestimate harms of treatment. What if they knew the truth? | The Incidental Economist
One reason most people overestimate the benefits of treatment and underestimate the harms is that the medical care industry is a rigged game. It is about doing things to people, rather than for them, because that’s how everyone (except the patient, very often) makes out financially; if the patient is diligent and lucky he or she achieves an outcome that they value, which could be quite different from the outcomes used to reward providers. The medical care marketing machine is ubiquitous and powerful. Unfortunately, the current debate about overdiagnosis and overtreatment is not cutting very deeply into healthcare excess, for the simple reason that there is too much money to be made by pharma, hospitals, doctors, and health plans.
The smarter you are about how the healthcare industry makes its money (or takes your and your employer’s money), the better off you will be. The path to successful interaction with the medical care machine lies in skeptical, minimalist interaction.
Despite the existence of metrics to help patients appreciate benefits and harms, a new systematic review suggests that our expectations are not consistent with the facts. Most patients overestimate the benefits of medical treatments, and underestimate the harms; because of that, they use more care.
With all the incompetence, innumeracy, illiteracy and downright dishonesty we’ve documented in this field and with all the employee dissatisfaction, revolts and lawsuits, one can’t help but wonder: Why?
Why would any employer do this to their employees?
Why aren’t vendors held to minimal standards of competence?
Why do vendors and consultants caught lying simply double down on the lies and/or ignore questions about their lies–knowing full well they’ll get away with it because workplace wellness has nothing to do with actual wellness so no one cares that it doesn’t work?
Why are benefits consultants allowed to lie about outcomes for their partnered vendors?
Why, after they get caught lying, do they win awards for those very same outcomes?
Why doesn’t anyone care that much of what they say and do is wrong?
Why doesn’t anyone care that poking employees with needles far more than the USPSTF advises produces no savings?
Why put up with the morale hit from disgruntled employees and possible lawsuits?
Bravo to Bravo for admitting the reason: It’s to claw back insurance money from employees by making programs so unappealing and requirements so onerous that many employees would rather forfeit their money than have anything to do with them. Here are Bravo’s exact words:
You might say, they don’t actually “admit” it. Well, obviously they aren’t going to skywrite it. But how else would one interpret this comment? Obviously they aren’t going to save money right away by “playing doctor” and poking employees with needles. Especially because they aren’t even adhering to legitimate preventive services guidelines, such as those from the United States Preventive Services Task Force (USPSTF).
They also still subscribe to the urban legend that 75% of an employer’s spending is lifestyle-related, even though that myth has long since been discredited as meaningless and misleading for employers.
Creatinine and thyroid screens are not recommended by the USPSTF, so they shouldn’t be done at all, let alone provide the basis for claiming savings. So, we have eliminated everything except the obvious: employers get to collect fines for employees who care too much about their health and/or their dignity to submit to Bravo’s offer to play doctor.
This is the classic example of wellness done to employees instead of for them. The Bravo website is sprinkled with discussions of appeals processes for employees who face punishments for the crime of weighing too much and/or other personal shortcomings having nothing to do with work performance (and precious little to do with healthcare spending during the working years)…but everything to do with transfering wealth back to the owners.
As is our policy, we offered Bravo a chance — and $1000 — to provide an alternate explanation in a timely way, which they didn’t. Two differences between that forfeiture and Bravo’s punishments: Bravo lost their $1000 (of our money) for simply being unwilling to jot down a few words, whereas they brag about fining employees $1000 (of their money) for not being able to lose weight and keep it off, which is far harder than writing down a few words. And the other difference about the $1000? Having just raised $22-million, Bravo won’t miss it.
August Update: As a result of this expose, Bravo has taken all this stuff off their website. They no longer brag about fining employees, they no longer discuss their appeals process at length on their site and they no longer pitch their D-rated lab tests like creatinine and thyroid. This is typical vendor behavior after getting caught. Score one for They Said What.