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How to Ensure Honesty on a Tobacco Attestation Form

How to Ensure Honesty on a Tobacco Attestation Form

So, your company is ready to implement an incentive or a tobacco surcharge on insurance for employees who use tobacco products.

The next task at hand is identifying individuals eligible for the incentive or premium discount. To achieve this, many organizations rely on self-reported data through a tobacco attestation form.

But how do you ensure employees are truthful about their tobacco use on these forms?

This is a common question we hear from clients, and addressing it requires a nuanced approach.

Here are 3 key considerations when using a tobacco attestation form:

1. Clearly articulate the definition of tobacco use

Definitions of tobacco products typically include, but are not limited to, cigarettes, e-cigarettes, vaporizers, cigars, cigarillos (or little cigars), pipes, chewing tobacco, snuff, hookahs, and other tobacco products.

However, many clients will consider employees to be “tobacco-free” if they are using Food and Drug Administration-approved nicotine patches, gum, or lozenges to quit using tobacco products. If they do this, they call it out on their tobacco attestation form.

To determine what definition is right for your organization, refer to your company goals and legal counsel.

2. Consider linking responses to your employee code of ethics

We see several companies tie tobacco use reporting to their code of ethics.

One client, for example, has employees sign a pledge to be tobacco-free throughout the year. Those using tobacco can either commit to becoming tobacco-free or fulfill a reasonable alternative standard (RAS) within a specified timeframe.

A RAS is an evidence-based program that can reasonably be expected to help someone quit. It’s required if a company applies a tobacco surcharge to the premiums of tobacco-using employees. Failure to complete the RAS or unwillingness to pledge tobacco-free status results in a tobacco surcharge.

This client reinforces its code of ethics during annual enrollment, emphasizing that intentionally providing false or misleading information constitutes a breach of the company’s ethical standards.

Consequences for falsifying tobacco status for this client extend to the revocation of discounts, repayment of discounted premiums, and the potential for disciplinary actions. Discipline can also include dismissal from the company.

3. Acknowledge (with compassion) the possibility of relapse

What should you do when employees claim they are tobacco-free, but colleagues report observing them smoking or vaping?

Begin by revisiting the definition of being tobacco-free, as outlined in your policy. Whether it’s measured in intervals of 30 days, 3 months, 6 months, or other durations, clarity on the timeframe is crucial.

Next, I’d encourage you to consider the nature of addiction—and understand that relapses happen. An employee might have been tobacco-free for 30 days, experienced a brief relapse with a couple of cigarettes, and then recommitted to quitting.

Each example should be taken on a case-by-case basis. Remember that most tobacco users WANT to quit, they just don’t always know what steps to take to get there successfully, and for good. Incentives and surcharges work best when they are used as motivators to continue the path to a tobacco-free life, not as punishment for slipping.

As employers who are concerned about the overall wellbeing of employees, it is important to recognize that quitting smoking can take 6 or more attempts, especially during stressful periods. Life’s challenges may trigger relapse back to tobacco use as a coping mechanism.

Therefore, it’s vital to provide a program that offers continuous support and allows for unlimited quit attempts. Always keep your focus on the ultimate goal: helping individuals lead tobacco-free lives.

Want more tips?

For more tips on how to structure your tobacco surcharge or incentive program to successfully engage employees, please view our on-demand 30-minute webinar Tobacco Surcharges and Incentives: What Works to Contain Costs and Increase Engagement.

Interested in a sample tobacco attestation form? We have that, too. Simply download Tobacco Surcharges: A Comprehensive Toolkit for Employers.

And if you’re ready to talk to an expert about how to roll out or redesign your tobacco surcharge program, please contact us today. The EX Program serves as a reasonable alternative standard and has helped nearly 1 million tobacco users develop the skills and confidence to live tobacco free.


Jessie Saul, Ph.D.

Director, Strategic Insights

Dr. Jessie Saul brings 19 years of experience in research, program evaluation, and strategic implementation around tobacco cessation. She applies this deep understanding to improve EX Program performance and reduce tobacco use among populations. She earned her Ph.D. in Science and Technology Studies from Cornell University.

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