New York City District Council of Carpenters Benefit Funds
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Retirement Planners and Administrators (RPA)
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Fringe Benefit Group
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TPA Retirement Plan Consultant EPIC RPS (TPA/DPS)
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Defined Contributions Compliance Consultant Loren D. Stark Company (LDSCO)
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Great Lakes Pension Associates, Inc.
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Retirement Solutions Specialists
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Greenline Wealth Management
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Where There's Smoke There's Questions: Designing Compliant Wellness Programs That Target Tobacco Use
Verrill Dana LLP [Guidance Overview] May 21, 2015 "[1] Is it acceptable to design a program where employees who use tobacco may avoid a higher insurance premium (or surcharge) only by quitting tobacco use? No.... [2] Are there any limits to the 'reasonable alternative standard' an employer can require for tobacco users to obtain the reward? Yes.... [3] Is it acceptable to design a program that restricts participation in certain health benefit options to employees who are tobacco-free (i.e., maintain a tobacco-free 'threshold' requirement for participation in certain health plans)? Generally, no.... [4] Does it matter whether an employer characterizes the different treatment of employees who use tobacco (and refuse to complete an alternative standard) and tobacco-free employees as a penalty or a reward? No." |
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