Participatory programs are exactly what they sound like-they are programs where "Either no reward is offered, or none of the conditions for obtaining a reward are based on an individual satisfying a standard related to a health factor". Employees aren't required to participate in the programs and won't penalize employees for not participating. This complies with non-discrimination requirements of HIPAA. Health-contingent programs on the other hand " require participants to satisfy a standard related to a health factor in order to obtain a reward". Health-contingent programs can be divided further into activity-only and outcome-based. The article goes into more details about the individual requirements for health-contingent programs so that they comply with the nondiscrimination rules.
Other factors wellness programs need to consider are whether or not they are "reasonably designed to promote health and prevent disease". A lot goes into healthcare regulations, and wellness programs are just another part of the overall system that has to make sure it meets ACA regulations and HIPAA guidelines. Read the document for more information!
