𝐈𝐍𝐒𝐔𝐑𝐀𝐍𝐂𝐄 𝐃𝐈𝐒𝐂𝐎𝐔𝐍𝐓𝐒 𝐟𝐨𝐫 𝐂𝐎𝐕𝐈𝐃-𝟏𝟗 𝐕𝐀𝐂𝐂𝐈𝐍𝐀𝐓𝐈𝐎𝐍𝐒 (𝟏𝟏/𝟑/𝟐𝟎𝟐𝟏)

A group health plan (or health insurance issuer offering coverage in connection with a group health plan) can offer plan participants a premium discount for receiving a COVID-19 vaccination.

The premium discount must comply with the final wellness program regulations. A premium discount that requires an individual to perform or complete an activity related to a health factor, in this case obtaining a COVID-19 vaccination, to obtain a reward would be considered a wellness program that must comply with the five criteria for activity-only wellness programs described in final wellness program regulations.

To satisfy these criteria, a wellness program that provides a premium discount to individuals who obtain a COVID-19 vaccination must be reasonably designed to promote health or prevent disease and must provide a reasonable alternative standard to qualify for the discount.

For example, the wellness program may offer a waiver or the right to attest to following other COVID-19-related guidelines to individuals for whom it is unreasonably difficult due to a medical condition or medically inadvisable to obtain the COVID-19 vaccination in order to qualify for the full reward.

The plan must also provide notice of the availability of the reasonable alternative standard under the wellness program. Further, the reward the plan provides in connection with the vaccine incentive program must not exceed 30 percent of the total cost of employee-only coverage and must give individuals eligible for the program the opportunity to qualify for the reward under the program at least once per year.

For more info and requirements, see Question 3 at https://www.dol.gov/sites/dolgov/files/EBSA/about-ebsa/our-activities/resource-center/faqs/aca-part-50.pdf

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𝐓𝐡𝐨𝐦𝐚𝐬 𝐉𝐚𝐦𝐞𝐬 𝐂𝐚𝐫𝐫𝐨𝐥𝐥, 𝐏.𝐂. 𝐢𝐬 𝐚 𝐥𝐚𝐰 𝐟𝐢𝐫𝐦 𝐟𝐨𝐜𝐮𝐬𝐢𝐧𝐠 𝐨𝐧 𝐟𝐞𝐝𝐞𝐫𝐚𝐥 𝐚𝐧𝐝 𝐬𝐭𝐚𝐭𝐞 𝐭𝐚𝐱𝐞𝐬 𝐭𝐡𝐚𝐭 𝐩𝐫𝐨𝐯𝐢𝐝𝐞𝐬 𝐢𝐧𝐝𝐢𝐯𝐢𝐝𝐮𝐚𝐥𝐬 𝐚𝐧𝐝 𝐛𝐮𝐬𝐢𝐧𝐞𝐬𝐬𝐞𝐬 𝐰𝐢𝐭𝐡 𝐭𝐚𝐱 𝐡𝐞𝐥𝐩 𝐚𝐧𝐝 𝐬𝐨𝐥𝐮𝐭𝐢𝐨𝐧𝐬 𝐟𝐨𝐫 𝐭𝐨𝐝𝐚𝐲 𝐚𝐧𝐝 𝐭𝐨𝐦𝐨𝐫𝐫𝐨𝐰.

𝐓𝐡𝐨𝐦𝐚𝐬 𝐉𝐚𝐦𝐞𝐬 𝐂𝐚𝐫𝐫𝐨𝐥𝐥, 𝐏.𝐂. 𝐢𝐬 𝐚 𝐥𝐚𝐰 𝐟𝐢𝐫𝐦 𝐟𝐨𝐜𝐮𝐬𝐢𝐧𝐠 𝐨𝐧 𝐟𝐞𝐝𝐞𝐫𝐚𝐥 𝐚𝐧𝐝 𝐬𝐭𝐚𝐭𝐞 𝐭𝐚𝐱𝐞𝐬 𝐭𝐡𝐚𝐭 𝐩𝐫𝐨𝐯𝐢𝐝𝐞𝐬 𝐢𝐧𝐝𝐢𝐯𝐢𝐝𝐮𝐚𝐥𝐬 𝐚𝐧𝐝 𝐛𝐮𝐬𝐢𝐧𝐞𝐬𝐬𝐞𝐬 𝐰𝐢𝐭𝐡 𝐭𝐚𝐱 𝐡𝐞𝐥𝐩 𝐚𝐧𝐝 𝐬𝐨𝐥𝐮𝐭𝐢𝐨𝐧𝐬 𝐟𝐨𝐫 𝐭𝐨𝐝𝐚𝐲 𝐚𝐧𝐝 𝐭𝐨𝐦𝐨𝐫𝐫𝐨𝐰.

𝐖𝐖𝐖.𝐓𝐉𝐂𝐀𝐑𝐑𝐎𝐋𝐋-𝐋𝐀𝐖.𝐂𝐎𝐌