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New Guidance on COVID-19 Vaccine-Related Premium Surcharges and Discounts
Groom Law GroupLink to more items from this source
[Guidance Overview]
Oct. 6, 2021

"In the new guidance, the Tri-Agencies take the position (without explanation) that vaccine premium incentive programs are 'activity-only' health-contingent programs.... Similar to other non-tobacco premium incentives, vaccine incentives increase the cost of coverage for employer mandate purposes. This means that if the incentive is a premium discount, the discount is treated as not earned, and thus, affordability is based on the assumed increased premium cost for the participant."

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