Employers around the country are increasingly expressing interest in establishing on-site medical clinics as a health care option for their employees. According to the 2020 International Foundation of Employee Benefit Plans (IFEBP) Employee Benefits Survey, approximately 28.6% of public employers and 16.8% of all employers have already established on-site medical clinics for their workers. Additionally, many smaller employers have recently adopted or are considering adopting on-site primary health clinics (either self-administered or in partnership with a clinic group or on-site health care vendor) for their employees.

Employers cite the need to control costs under their major medical plan, shorten periods of absence and increase productivity in the workplace as reasons for adopting an onsite medical clinic model. Employers considering providing on-site health care services to employees and/or their dependents must consider the scope of services they will provide in such on-site facilities and who will be eligible to use those services.

For purposes of this discussion, on-site medical clinics include the following types of facilities:

• On-Site Medical Clinic – An employer-sponsored medical clinic located on the employer’s premises
• Near-Site Medical Clinic – An employer-sponsored medical clinic located near the employees’ worksite
• Shared-Site Medical Clinic – An employer-sponsored medical clinic that serves multiple employers or employer locations, generally in a near-site setting

The range of services provided by an on-site clinic may vary. On-site medical clinics may offer a range of primary health care services (acute or urgent care, preventive care and diagnostic testing similar to those available at chain grocery, retail and drug store clinics). For example, an employee might visit an on-site medical clinic to obtain the following:

• Diagnosis and treatment of certain minor illnesses and injuries
• Physical examinations, screening tests and vaccinations
• Medications
• Health care counseling, education and similar services

More comprehensive on-site clinics may include primary care, physical therapy, on-site pharmacies and behavioral health services. Some are paired with other wellness services and programs.

Employers with on-site clinics also frequently offer health care services to family members of their employees.

Providing health care services that exceed the first aid facility exception (see on next page) leads to the creation of a group health plan, resulting in certain legal obligations and compliance requirements for plan sponsors.

Regulatory and Legislative Strategy Group