As of 2023, roughly 60% of individuals under the age of 65 had employer-sponsored health insurance coverage. Such coverage may operate through a health insurance plan or be funded directly by the employer (i.e., a “self-funded plan”).
Is there a requirement?
Federal laws and regulations do not currently require employer-sponsored plans to provide coverage or payment for FIM services.
Are there voluntary pathways?
As with Medicaid and Medicare, pathways exist for employer-sponsored plans to integrate payment for FIM interventions.
More information about these voluntary options—as well as legal parameters and considerations—were recently outlined in a June 2025 report from the Milken Institute titled A Blueprint for Employer-Led Food as Health Strategies. Plans interested in implementing these pathways can consult this new report for additional details.
Path 1: Disease Management Programs
Goal:
Provide individualized, structured treatment plans for employees with chronic conditions through a multidisciplinary care team, integrating education, medication-adherence support, and lifestyle modifications (such as healthy eating and physical activity), along with regular monitoring of biomarkers and behavior change.
Purpose:
Enable employers to support employees with chronic conditions offering programs through their health plan or specialized partner organizations—most commonly diabetes, hypertension, and cardiovascular disease management programs.
Allowance:
Can serve as a core component of a FIM intervention by incorporating nutrition support such as produce prescriptions, healthy meal kits, MTM, and nutrition education.
Availability:
Widely offered among employers with health benefits (~64% of large firms and 36% of small firms). An emerging share of employers are explicitly integrating FIM features as they seek nutrition-based strategies to reduce chronic disease costs and improve health outcomes.
Path 2: Participatory Wellness Programs
Goal:
Promote healthier eating habits and improve overall well-being by giving all employees easy access to nutritious foods and supportive nutrition resources.
Purpose:
Offered to all employees as a voluntary wellness benefit that encourages healthier lifestyles, supports prevention, and enhances daily functioning without tying participation to a specific condition.
Allowance:
Offered through a health plan or as a stand-alone employer wellness program and open to any employee who wishes to participate, regardless of health status. Examples include: free or discounted grocery delivery, produce boxes or healthy meal kits, access to health coaching or digital nutrition tools.
Availability:
As of 2024, many firms that provide health benefits also offer one or more wellness/lifestyle programs including programs to support healthy behaviors like nutrition, weight management, or lifestyle coaching. About 23.1% of U.S. worksites offer a “nutrition/ healthy‑eating” program as part of their wellness offerings. Offering healthy‑eating support is more common among larger employers. Firms with 500+ employees have a higher percentage offering a nutrition program.
Path 3: Health-Contingent Wellness Programs
Goal:
Reward employees for participating in wellness activities or achieving specific health outcomes.
Purpose:
- Activity‑only programs: Employees complete a health-related activity (e.g., nutrition counseling) to receive a reward, without needing to meet a specific health target.
- Outcomes‑based programs: Employees must attain or maintain a defined health outcome (e.g., managing blood sugar or blood pressure) to earn the incentive.
Allowance:
Programs must comply with HIPAA nondiscrimination rules, including: designed to improve health or prevent disease, employees must have at least one chance per year to earn the incentive, incentives capped at 30% of total coverage costs, provide other ways to qualify.
Availability:
Health‑contingent wellness programs are less common than other wellness programs with only about 7% of large employers report offering them through their health plan. Among employers offering these programs, incentives (monetary or otherwise) are more often used for participation (e.g., completing a health‑risk assessment or lifestyle activity) than for meeting health outcomes.
◀ FIM in Medicare