Compensation Strategies Group, Ltd.
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|Wellness Plans Incentivizing COVID-19 Vaccinations Could Trigger ACA Penalties|
Sept. 1, 2021
"The clear language of the existing regulations ... would result in any wellness program incentivizing a COVID-19 vaccination to increase the amount the employer must report to the IRS on line 15 of the Form 1095-C by the amount of the penalty being imposed on employees who are not vaccinated.... [E]ven a fully vaccinated employee would have to have his/her amount that is to be reported by the employer on line 15 of the Form 1095-C increased by the amount of the penalty as the wellness program would not relate to tobacco use! ... This would have a dramatic impact on who would be eligible to receive a premium tax credit as a result of the employer's offer of coverage not meeting the ACA's affordability definition."
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