Premium discounts for employees who are vaccinated?

HHS, DOL, and IRS jointly said that a group health plan offering a discount to vaccinated employees is a “wellness plan” because it requires an individual to perform or complete an activity related to a health factor, in this case obtaining a COVID-19 vaccination, to obtain a reward (a premium discount). As such, the arrangement must satisfy certain criteria for a wellness program, including that the reward the plan provides in connection with the vaccine incentive program must not exceed 30% percent of the total cost of employee-only coverage and must give individuals eligible for the program the opportunity to qualify for the reward under the program at least once per year. #IdeaoftheDay