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| New Guidance on COVID-19 Vaccine-Related Premium Surcharges and Discounts Groom Law Group  [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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