Comment on FR Doc # 2012-28361

“Incentives for Nondiscriminatory Wellness Programs in Group Health Plans” could be expanded to encourage positive wellness, as contrasted with the medical nature of worksite offerings. Usually, incentives are offered for employees to stop smoking, attain baseline results on biometric screenings and/or meet targets for exercise, weight and so on. I’d like to see rules to encourage the evolution of worksite wellness from disease management, risk reduction and preachy health education geared to cost containment to some measure of REAL wellness. Such offerings would be more likely to improve health. Guidelines could invite programming for quality of life with elements that promote joy, exuberance, personal freedoms and life-enrichments. Also, to shift attention to culture change from individual heroics. I would like to see guidelines that promote the arts of reason (effective decision-making), gaining a better understanding and more frequent experience of exuberant living, experiencing the joys of athleticism (focused on exercise and sound whole foods plant-based nutrition) and expanding awareness of elements of individual liberty and personal freedoms.   More is at stake than the appropriate level of reimbursements for carrot-like incentives. Needed are expansive ideas, not restrictive controls over the minutia of medical risk reduction activities and incentive designs. The fourth requirement (under “reasonable design”) is where the guidelines with wise conceptual advice could have the most impact in shaping wellness programming at worksites.              Given the state of workplace wellness, I don't think there should be any health contingent program incentives. Anyone who has to be rewarded for not smoking, abusing substances, losing weight, exercising or the like is not likely to take complementary, health-enhancing actions or even sustain whatever it is he's being incentivized to do. Not for very long, anyway.