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| Guidance Clarifies HIPAA Hurdle Regarding Group Health Plan Premium Vaccination Incentive Programs Bond, Schoeneck & King  [Guidance Overview] Oct. 14, 2021 "Employers considering significant premium surcharges for unvaccinated individuals should take steps to ensure that the surcharge both complies with the HIPAA limit (i.e., 30% of the employee-only premium) and to understand whether the surcharge would result in the premium offer becoming unaffordable under the ACA for impacted employees." |
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