Wellness Programs Providing Benefits to Those Not in Health Plan

[401 Chaos]

This seems like it should be an easy or simple question but I cannot seem to find any express discussion or guidance on this and so want to make sure I am not missing something. Company has a group health plan. Company is going to implement a wellness program. It is generally separate from the group health plan and will be available to all employees. It will reward individuals for achieving certain health status / factors (i.e., it is not a participation only program--you have to achieve a particular result or alternative standard). The plan generally complies with the five factor HIPAA nondiscrimination requirements--the reward involved is relatively small and there are alternative arrangements. Plan is to provide premium discounts or rebates for those in the group health plan and cash / card for those individuals achieving health status that are not in the group health plan (e.g., if covered by a spouse's plan, etc.).

Is there a problem with providing cash / rewards to those not in the group health plan since the cost of coverage for them is $0 and any amount would exceed 20% or is the 20% to be determined based on general cost of coverage for an employee / family under the plan if they were covered?

Thanks

[Guest shawn8]

Hello Guys i think that the basic idea is to break out the health plan into two items, one concentrating on health and fitness and the other on sickness. The group of experts that supporters for the crack out suggests such a carve-out allows and appearance of health and fitness advantages designed to create a healthy employees.Thanks a lot!!