Our clients have been asking us for recommendations for no- and low-cost incentives for their wellness programs for years, and now the Equal Employment Opportunity Commission (EEOC) has come out with proposed guidance for these wellness incentives, suggesting a significant shift for many wellness programs to de minimis incentives only. The alert addresses what type of incentives can be offered without violating the Americans with Disabilities Act (ADA) or the Genetic Information Nondiscrimination Act (GINA), stating that “allowing too high of an incentive would make employees feel coerced to disclose protected medical information to receive a reward or avoid a penalty.”

Viewpoints from Claire Letourneau

Naturally, there’s been an uptick in recommendation requests since the alert release – but there are plenty of reasons to consider de minimis incentives aside from the ADA and GINA implications.

Many wellness budgets have been cut due to COVID-related losses, and while we’ve helped our clients take advantage of free medical carrier wellness programming they have no budget to incentivize participation. Other employers have a limited medical carrier wellness fund to use but still require “free” incentives. Some of our clients offer an incentive for medical plan members through HSA contributions or premium rebates but desire an additional option for all employees.

Regardless of your situation, we encourage getting ahead of the curve. Here are some no- and low-cost incentive ideas to help motivate your employees:
No-cost options:
  • Priority Parking Spots – set aside high-priority parking spaces to be temporarily gifted to wellness participants
  • Certificates of Success – share these with employees and keep them in their HR materials to be considered during annual performance reviews
  • Winner’s Pick – if you’re offering a series of wellness webinars or challenges, let the winning team select an upcoming webinar topic or challenge focus
  • Wellness Badges – like a buckeye on the helmet of an Ohio State football player, share wellness badges to be displayed on a cubicle, office door, email signature, or Zoom background to demonstrate their commitment to a healthy workplace
No-cost-but-time options:
  • Wellness “hours” – everyone values time off, so consider giving wellness hours to be cashed in for early sign-off/leave from work with supervisor approval. Reinforce that self-care is an important facet of everyone’s wellbeing
  • Coffee or lunch with “the boss” – offer a virtual meet with an important figure at your company. Leaders can give insights into the business, but more importantly, can get to know their health-minded employees (and vice versa)
Low-cost options:
  • An EEOC fave, water bottles – think about company-branded or higher-tech versions like vacuum-sealed or fruit-infusing bottles
  • $5 gift cards – employees love to get something, even if it’s just a few dollars toward their next coffee or lunch
  • Massage therapy balls – these come in different shapes, densities and textures and are excellent for recovery and relieving muscle pain when a massage is not available (not to be confused with soft, squeezy stress balls!)
  • Resistance exercise bands or yoga mats – help employees work out from the convenience of their homes
  • Nutrition gadgets – gift a pressure cooker or a 10-cup food processor to help employees cook at home
  • App subscription – award a subscription to an app for mindfulness/meditation, meal delivery or fitness
  • Books – whether on a given wellness topic or a blank journal, both are great options for relaxation
Consider your company’s unique culture, senior leadership support, budget and time to administer these incentives. Better yet, survey your employees!

Get them engaged in planning the experiences and incentives that mean the most to them. The EPIC Wellness & Heath Management team is always ready to jumpstart these conversations and keeps a constant eye on EEOC guidance to ensure your wellness efforts are compliant.


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EPIC offers these opinions for general information only. EPIC does not intend this material to be, nor may any person receiving this information construe or rely on this material as, tax or legal advice. The matters addressed in this article and any related discussions or correspondence should be reviewed and discussed with legal counsel prior to acting or relying on these materials.


Our Leaders

Claire Letourneau Headshot
Claire Letourneau

Senior Account Executive, Wellness – New York, NY