• Public Affairs

  • ACOEM Comments to Healthy People 2020

    December 31, 2009

    Office of Disease Prevention and Health Promotion
    Office of Public Health and Science
    Office of the Secretary
    Department of Health and Human Services
    Washington, DC 20201

    To Whom It May Concern:

    The American College of Occupational and Environmental Medicine (ACOEM) is pleased to provide comments for consideration in the development of the goals and objectives for Healthy People 2020.

    ACOEM represents more than 5,000 physicians specializing in occupational and environmental medicine. Founded in 1916, ACOEM is the nation’s largest medical society dedicated to promoting the health of workers and the environment through the practice of medicine. Training in occupational and environmental medicine provides skill in clinical, environmental and occupational medicine, toxicology, epidemiology and biometry. In addition, practitioners understand how to enlist and collaborate with the skills of colleagues from industrial hygiene, toxicology, occupational health nursing, safety engineering, industrial relations, health physics, ventilation engineering, mechanical engineering, biomechanics, law, public policy, and health education.

    In 2009, ACOEM launched a major initiative designed to change federal policies in order to make health promotion and disease prevention in the workplace a much higher priority than ever before. Titled “Healthy Workforce Now,” the initiative includes a multi-pronged advocacy agenda ranging from working to change policies in Washington, D.C., to providing new education and resources to help employers promote health and wellness in the workplace.

    We hope that a Healthy Workforce will be an integral part of Health People 2020.

    Attached are ACOEM’s comments and recommendations on the following topic areas:

    • Access to Health Services
    • Arthritis, Osteoporosis, and Chronic Back Conditions
    • Disability and Secondary Conditions
    • Educational and Community Based Programs
    • Immunization and Infectious Diseases
    • Nutrition and Weight Status
    • Occupational Safety and Health
    • Physical Activity and Fitness

    The comments and recommendations have also been submitted on line.

    ACOEM looks forward to participating in Health People 2020.  If we can provide any additional information, please contact Patrick O’Connor, ACOEM’s Director of Government Affairs. He can be reached at 202-223-6222 or by email at patoconnor@kentoconnor.com.

    Eisenberg - new 
    Barry Eisenberg
    Executive Director



    ACOEM Comments to Healthy People 2020 

    Topic Area: Access to Health Services 

    Proposed New Objectives 

    • Encourage delivery of primary care services at the workplace. 

    ACOEM Comments: Primary care services provided at the workplace can certainly incorporate all of the following components of the Patient Centered Medical Home (PCMH) model to drive improvements in health and productivity along the entire continuum of health promotion, acute and chronic care, and disability management: accessible comprehensive primary care, a team-based approach, coordination of care, a focus on quality and safety, and a health information technology platform to support the successful achievement of population-level health outcomes.

    On-site primary care improves health outcomes and reduces costs through the following mechanisms:

    • Diagnosis and treatment can be performed at lower unit costs compared to community providers.
    • Utilization of evidence-based treatment practices to enhance quality outcomes.
    • Easily accessible, on-site treatment will limit unnecessary visits to emergency rooms as well as visits to inappropriate and multiple providers.
    • Early intervention by on-site providers may limit the duration of absence and enhance productivity.

    On-site urgent care services, preventive services and occupational medicine services can reduce emergency department visits overall and may reduce inappropriate use of the emergency department – thus, allowing greater throughput of patients who are appropriate for an emergency department.

    • Reimbursement for Preventive Services Provided at the Worksite. 

    ACOEM Recommendation: Encourage health care plans to reimburse physicians and other health care providers for preventive services provided to employees at the worksite, when such services have been requested and directed by the employer.

    • Increase funding for residency programs in occupational medicine.

    ACOEM Recommendation: Trained occupational medicine specialists are vital to ensure that America’s employed population is protected from work-related injuries and illnesses. An estimated 110 million Americans go to work every day. Physicians who specialize in occupational medicine parallel the general public health system in dealing with illnesses and injuries in workplace populations, including health promotion and combating the incidence rates of obesity, diabetes, heart disease, cancer, and other chronic diseases. In the new global economy, occupational physicians are being asked to fulfill new, demanding roles: to maintain workforce health and productivity, to ensure workplace preparedness against disasters, and to manage health care expenditures.

    Topic Area: Arthritis, Osteoporosis, and Chronic Back Conditions 

    Proposed New Objective 

    • Worksite Ergonomics and the Aging Workforce 

    ACOEM Comments: In the settings of an aging workforce, individuals working into their 60s and 70s, workplace ergonomics programs and preventive strategies have the potential to reduce and prevent injury and disability.

    Topic Area: Disability and Secondary Conditions 

    Proposed New Objectives 

    • Modified Duty Strategies in the Workplace 

    ACOEM Recommendation: Healthy People 2020 should propose to the Joint Commission a requirement for implementation of modified duty programs as a strategy to promote early return to work and disability prevention in health care settings. Occupational and environmental (OEM) physician integration/interaction in the PCMH model would enhance the coordination of care that is necessary in operationalizing modified duty strategies.

    • Work-Related Disabilities 

    ACOEM Recommendation: Address early return to work through modified or transition duty as a strategy to limit work-related disability.

    Data Source: Preventing Needless Work Disability by Helping People Stay Employed. Copyright©2006 American College of Occupational and Environmental Medicine. Published in September 2006 JOEM. www.acoem.org/guidelines.aspx?id=566 

    Topic Area: Educational and Community Based Programs 

    Objectives Retained But Modified From Health People 2010 

    • ECBP HP2020–5: Increase the proportion of worksites that offer a comprehensive employee health promotion program to their employees. 

    ACOEM Comments: The employer benefits when they can provide resources to keep the healthy employees healthy and modify the health status of the less healthy employee. Employers need to be educated in the concept of presenteeism and the effect it has on total cost of employee health. The worksite is an efficient means of delivering these types of services. Employers may find the use of these programs may affect the direct cost of providing benefits decrease.

    Additional information on the benefits of workplace health promotion and prevention programs is available at www.healthyworkforcenow.org 

    • ECBP HP2020–6: Increase the proportion of employees who participate in employer-sponsored health promotion activities. 

    ACOEM Comment: Employees should be encouraged to participate in employer sponsored health activities. Employers should provide incentives to their employees to participate in the health promotion activity. Employees need to recognize the concept of developing a culture of health at the work.

    Objectives Moved from Another Healthy People Topic Area 

    • ECBP HP2020–10:  Increase the inclusion of sentinel core competencies in health promotion and disease prevention in health profession training. 

    ACOEM Comments: Core competencies should include a comprehensive curriculum on health and productivity management (HPM) for all healthcare professionals including medical, nursing, physician assistant, pharmacy and dental students. The primary benefit of health intervention/HPM training and programs will be educate all health professionals on the value of promoting healthy lifestyles among workers and in the workplace as well as reduce medical costs and work absenteeism and presenteeism due to chronic medical conditions.

    Proposed New Objective 

    • Employee Health and Productivity 

    ACOEM Recommendation: The American health care system faces enormous challenges and is on a collision course with several economic and demographic trends that have dire consequences for the nation. Health care costs are rising dramatically just at the time when the so-called “silver tsunami” is arriving in the form of millions of aging baby boomers who are exiting the workforce. This population will no longer help fund Medicare and Social Security systems through payroll taxes, and at the same time it will begin to utilize these systems heavily, due to a growing burden of illness and health conditions.

    The impact of health conditions on America’s competitive position in the world is sobering. Without a healthy, able and available workforce, the United States will find it impossible to thrive in an increasingly competitive global marketplace. Employers of all sizes and types increasingly are using strategies based on the relationship between health and productivity to lower health risks, reduce the burden of illness, improve wellness and human performance, and enhance the quality of life for workers and their families, while reducing total health-related costs. Such programs help employers more accurately determine which health conditions have the greatest impact on overall productivity and then design strategies to help their employees prevent or better manage these conditions.

    The workplace offers unique resources and infrastructure for addressing these problems.

    The Workforce Health and Productivity Summit held in November 2008 and co-hosted by ACOEM produced ten Consensus Statements that form the nucleus of a national agenda intended to raise awareness and understanding of health and productivity and create a healthier, more productive American workforce:

    • The health of the workforce is inextricably linked to the productivity of the workforce and therefore ultimately linked to the health of the economy. This important relationship between health and productivity has significant implications for national health policy and should become a part of the nation’s health-reform debate.
    • Continuing the status quo of current healthcare strategies in the workplace is not a sustainable option; the realities of the economic burden of health risks and health conditions, rising total costs and an increasingly competitive global marketplace require an urgent shift to integrated health and productivity improvement strategies.
    • A strong body of evidence has emerged in recent years, offering employers proven strategies for more effectively managing the health of the workforce and recognizing the strong link between health and productivity.
    • Successful integrated health and productivity improvement initiatives are built upon well-established, recognized principles.
    • The impact of a healthier, more productive workforce is quantifiable; when combined with other business measures it helps determine the overall economic value of an enterprise. The business community, ranging from financial analysts to investors, should develop and institutionalize additional accounting and valuation methods that include health and productivity metrics to more accurately determine the business value of workforce health assets in a company.
    • As an evolving discipline, integrated health and productivity measurement methodologies should be studied continuously, improved and more consistently applied.
    • Employers need to have a consistent, ongoing approach for measuring and benchmarking their results as they design and implement integrated health and productivity improvement initiatives.
    • The concept of evidence-based medicine has grown more commonplace in U.S. health care. However, the evidence used to determine best practices needs to go beyond clinical outcomes and include functional impacts on health and productivity.
    • Engagement and participation of the workforce is essential to successful design and implementation of health and productivity improvement initiatives.
    • Health is determined by a wide range of factors, some of which cannot be addressed through medical and/or behavioral intervention. Broad social and environmental determinants – ranging from food and transportation systems to cultural practices – can influence health.

    Proposed Data SourcesSerxner S, et al. Do employee health management (EHM) programs work? AJHP. 2009;23(4).

    Loeppke R. The value of health and the power of prevention. Int J Workplace Health Manage. 2008;1(2:)95-108.

    Loeppke R, Nicholson S, et al. The impact of an integrated population health enhancement and disease management program on employee health risk, health conditions and productivity. Population Health Manage. 2008:11(6); 287-96.

    Goetzel R, Ozminkowski R. The health and cost benefits of work site health-promotion programs. Annual Rev Public Health. 2008;29:303-23.

    Naydeck, B, et.al. The impact of the highmark wellness programs on 4 year healthcare costs. J Occup Environ Med. 2008;50(2):146-56.

    Burton W, Chen C, Conti D, Schultz A, Edington D. The association between health risk change and presenteeism change. J Occup Environ Med. 2006;48:252-63.

    Burton W, Chen C, Conti D, Schultz A, Edington D. Measuring the relationship between employees’ health risk factors and corporate pharmaceutical expenditures. J Occup Environ Med. 2003;45:793-802.

    Aldana SG. Financial impact of health promotion programs: a comprehensive review of the literature. Amer J Health Promotion. 2001;15:296-320.

    Edington D. Emerging research: a view from one research center. Amer J Health Promotion. 2001;15:341-9.

    Goetzel R, Anderson D, Whitmer R, Ozminkowski R, Dunn R, Wasserman J. The relationship between modifiable health risks and health care expenditures: an analysis of the multi-employer HERO health risk and cost database. J Occup Environ Med. 1998;40:843-54.

    Topic Area: Immunization and Infectious Diseases 

    Proposed New Objective 

    • Increase the proportion of healthcare workers who are vaccinated annually against influenza and ever vaccinated against pneumococcal disease. 

    ACOEM Comment: Increase the Healthy People 2010 goal of vaccinating 60% of health care providers against influenza to 80%. OEM physicians are positioned to collaborate with public health officials, healthcare organization senior management and infection control colleagues to provide a safe and healthy environment for patients and healthcare workers.

    Topic Area: Nutrition and Weight Status 

    Proposed New Objective 

    • Worksite nutrition and weight management counseling. 

    ACOEM Comment: Increase the proportion of worksites that offer nutrition or weight management classes or counseling.

    Topic Area: Occupational Safety and Health 

    Proposed New Objective 

    • Increase funding for occupational medicine residency programs. 

    ACOEM Recommendation: Increase funding for residency programs in occupational medicine that provide training in – 1) the recognition, management and prevention of occupational disease and injury; 2) investigative skills for evaluating causes of occupational disease and injury; and 3) other areas consistent with the recognized core competencies of occupational medicine.

    Proposed Data Source: The American College of Occupational and Environmental Medicine Panel to Define the Competencies of Occupational and Environmental Medicine. www.acoem.org/uploadedFiles/Publications/OEM_Competencies/ACOEM%20OEM%20COMPETENCIES.pdf 

    Topic Area: Physical Activity and Fitness 

    Proposed New Objective 

    • Encourage worksite-based exercise programs 

    ACOEM Comment: Increase the proportion of employed adults who have access to and participate in employer-based exercise facilities and exercise programs.