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Can You Offer Employees Incentives for Vaccination?
Miles & Stockbridge 
[Guidance Overview] June 18, 2021 "Under HIPAA, a vaccine incentive is likely to be considered a health-contingent wellness program. This kind of program is required to, among other things, [1] limit rewards to not more than 30% of the total cost of coverage under the employer's group health plan and [2] offer a reasonable alternative to satisfying the main condition.... [A] vaccine incentive program can be [1] incorporated into a HIPAA-compliant group health plan or [2] designed to be voluntary." |
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