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COVID-19 Vaccination Incentives and Surcharges OK'd in Group Health Plan Guidance
McGuireWoodsLink to more items from this source
[Guidance Overview]
Oct. 6, 2021

"Most employers are considering multiple entry points each plan year for participants who become vaccinated or even 'rolling' qualification for the incentive/removal of the surcharge. Some employers are also considering aligning new qualifying periods as the [CDC] releases additional guidance, for example, in the case of booster shots.... Employers should be cautious about offering incentives to/imposing surcharges on only select groups of employees."

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