For WorldatWork Members
- Considerations to Manage the Costs of GLP-1 Coverage, Workspan Daily Plus+ article
- Ready, Set, Go: Optimize Your Physical Well-Being Programs, Workspan Daily Plus+ article
- Rethinking the Status Quo to Improve Men’s Health, Workspan Magazine article
- How to Calculate the ROI on Your Wellness Program, Journal of Total Rewards article
- Workplace Well-Being Trends, research
For Everyone
- Increase Engagement in Diabetes Programs with Behavioral Economics, Workspan Daily article
- Most Employers Hold Firm on Well-Being Offerings — But Want Results, Workspan Daily article
- As Interest in GLP-1 Drugs Spikes, Employers Weigh the Costs, Benefits, Workspan Daily article
- Boldyn Networks Offers a Bolder Approach to Employee Well-Being, Workspan Daily article
- Health and Welfare Plans: Strategic Planning and Design, course
With November being designated as Diabetes Month in the United States — and Nov. 14 serving as World Diabetes Day — it may be the perfect time for total rewards (TR) professionals to:
- Focus their communications and initiatives on this prevalent and pervasive health issue; and,
- Provide benefits and resources to boost the health and well-being of the organization’s workforce.
The U.S. Centers for Disease Control and Prevention (CDC) estimates 38.4 million Americans (11.6% of the nation’s population) have diabetes. Of that total, 8.7 million adults aged 18 or older (or 22.8% of adults with diabetes) are undiagnosed. On a global scale, the International Diabetes Atlas estimates 589 million individuals between the ages of 20 and 79 are diabetic.
For employers and their TR pros, diabetes represents both:
- An ongoing and growing general health concern; and,
- A relatively high healthcare-related benefit expenditure exposure.
Access a bonus Workspan Daily Plus+ article on this subject:
The Costs and Concerns
According to Beth Stewart, the director of health, equity and well-being at consulting firm WTW, individuals with diabetes, on average, have healthcare costs two times higher than a person without the disease. Those costs directly impact both employees and employers. In addition, she noted, employers bear indirect costs tied to increased diabetes-related disability via higher rates of presenteeism and absenteeism.
Moreover, Stewart noted, the potential cost of 88 million adults with prediabetes (or 3.4% of adults in the U.S., according to the CDC) is not yet on the radar for many employers. It’s also not front-and-center for workers as, she said, 85% of impacted adults are unaware of their condition.
Another complication is the complexity of the disease. There are several types of diabetes (i.e., Type 1, Type 2, prediabetes, gestational diabetes), and each presents their own health challenges and have their own general treatment specifications.
“As the incidence of diabetes continues to rise, the direct and indirect budgetary impact on employers will grow accordingly,” Stewart said.
Compliance (and Caring) Considerations
The 2026 Health Cost Trend Survey from HR and benefits consulting firm Segal highlights two response strategies: implementing digital health coaching and addressing utilization of glucagon-like peptide-1 (GLP-1) medications, a naturally occurring hormone that plays a role in regulating blood sugar levels.
When implementing these and other strategies, U.S. employers need to consider that employees have workplace protections under the Americans with Disabilities Act (ADA) and the Health Insurance Portability and Accountability Act (HIPAA), as well as through the Equal Employment Opportunities Commission.
Kathryn Bakich, Segal’s senior vice president for health compliance, explained that HIPAA’s nondiscrimination provisions generally prohibit a group health plan from denying an individual eligibility for benefits or charging a higher premium based on a health factor like diabetes.
She added that employer plans can have wellness programs that vary benefits based on health status, as long as the program meets criteria including that the program be reasonably designed to promote health or prevent disease. In addition, she said, it must show that any supplied financial incentive does not exceed a targeted amount and that there is a reasonable alternative standard for obtaining the incentive for individuals who cannot meet the criteria due to medical reasons.
As an example, Bakich said a plan could waive its annual deductible for an employee with diabetes if the employee enrolls in a disease management program that consists of attending educational classes and following their doctor’s recommendations regarding exercise and medication.
“ADA rules, enforced by the EEOC, seek to assure that participation in a diabetes wellness program is voluntary,” she said. “The EEOC requires a notice to be provided to any employee eligible for a wellness program.”
Dov Lutzker, an attorney and partner with the Epstein Becker Green law firm, noted that the ADA covers private employers with 15 or more employees, so many employers likely need to be proficient on diabetes from a wellness, cost-containment, and legal and regulatory compliance perspective.
He said diabetes impacts people in myriad ways, but a person with diabetes is almost certainly a person with a disability under the ADA, even when controlled with insulin, medication and/or diet. He added that the law covers applicants and employees in hiring, firing, promotions or other employment actions, and requires keeping medical information confidential and separate from personnel files.
“Before a job offer, employers cannot ask about a medical condition, including diabetes,” Lutzker said. “After a job offer but before employment starts, employers can ask about health conditions if they ask all applicants in the same job category.”
For example, he said employers can ask about diabetes only if there is a legitimate concern about safety or job performance, or if the employee requests an accommodation.
Administering Accommodations
Lutzker explained that employers are required to provide reasonable accommodations to qualified employees (or applicants) with diabetes to enable them to perform their essential job functions — unless the accommodation would create an undue hardship.
Common accommodation examples include:
- Allowing breaks for individuals to check their blood sugar, and/or to eat, drink or take medication to control their blood sugar;
- Offering a private area for individuals to test blood sugar or administer insulin;
- Giving access to food, drink and supplies at the employee’s workstation; and/or,
- Providing a modified work schedule, shift change or leave to manage diabetes or go to related medical appointments.
Just like people with other types of disabilities, when an employee with diabetes requests a reasonable accommodation, Lutzker said, it is important to engage in an interactive process with the employee to determine their individual needs based on their particular functional limitations and job description.
“The accommodation that is right for one person may not be the same as for another employee,” he said.
Added WTW’s Stewart: “Employees with diabetes often bring the stress of managing their condition with them to the workplace. Therefore, it is essential for employers to make accommodations as warranted for [these] individuals.”
Offering Solutions
Employers can take advantage of integrated diabetes education and condition management programs through their health benefits partners, plus sponsor counseling from health advisors and digital tools. Diabetes Month is an opportunity for organizations to reevaluate diabetes interventions, which can increase productivity, reduce absenteeism and help to brand a company as a caring employer. For strategies and tools, check out the:
- The American Diabetes Association’s Resources for Employers; and,
- The Northeast Business Group on Health’s guides on tackling chronic conditions.
Editor’s Note: Additional Content
For more information and resources related to this article, see the pages below, which offer quick access to all WorldatWork content on these topics:
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