Can your firm offer employees a vaccine incentive via your health insurance premium?
A new FAQ from the DOL, Health and Human Service and the Treasury says yes!
So, if you still have unvaccinated employees, this may help , despite President Biden’s vaccine mandate.
Getting vaccinated against COVID-19 to get a reward is considered an activity-only wellness program for which specific conditions must be met.
What conditions?
There are five criteria your company must meet to take advantage of the vaccine incentive. The criteria for activity-only wellness programs include:
- You must “reasonably” design your program to promote health or prevent disease.
- You must provide a reasonable alternative standard to qualify for the discount. The feds’ example: A wellness program may offer a waiver or the right to attest to following other COVID-19-related guidelines to certain individuals. These are people for whom it’s unreasonably difficult due to a medical condition or medically inadvisable to obtain the vaccination to qualify for the full reward.
- The plan must also provide notice of the availability of that reasonable alternative standard under the wellness program.
- The reward tied to the vaccine incentive program can’t exceed 30% of the total cost of employee-only health coverage, and
- Eligible individuals must have the opportunity to qualify for the reward under the program at least once per year.
One thing you can’t do
There’s one thing the FAQ pointed out that you can’t do. And that’s condition eligibility for benefits or coverage for covered items or services to treat COVID-19 based on being COVID-19 vaccinated.
Plans and issuers are prohibited from discriminating against participants, beneficiaries, and enrollees when it comes to eligibility, premiums or contributions based on health factors.
Therefore, “all similarly situated individuals” must be provided benefits under this plan.
