On October 4, 2021, the Department of Labor (DOL), Health and Human Services (HHS) and the Treasury (Departments) issued FAQs addressing rules regarding premium incentives for COVID-19 vaccinations and rapid coverage of preventive services for COVID-19.
The FAQs clarify that a group health plan (of health insurance issuer offering coverage in connection with a group health plan) may offer participants a premium discount for receiving a COVID-19 vaccination. However, plans generally may not condition eligibility for benefits or coverage on vaccination status, and any discount must comply with the final wellness program rules.
Under these rules, a premium discount that requires an individual to obtain a COVID-19 vaccination would be considered an activity-only wellness program, which is a type of health-contingent wellness program. These programs must comply with the regulations’ five nondiscrimination criteria, including an incentive limit and a requirement to offer a reasonable alternative standard in some cases.
The maximum permissible reward (or penalty) under a health-contingent wellness program that is part of a group health plan (and is not related to tobacco use) is 30% of the cost of coverage.
According to the FAQs, effective January 5, 2021, plans and issuers must cover, without cost sharing, an COVID-19 vaccines and their administration immediately once the particular vaccine becomes authorized under an emergency use authorization (EUA) or approved under a biologics license application (BLA). This coverage must be provided consistent with the scope of the EUA or BLA, including any amendment, such as to allow for an additional dose to certain individuals, booster doses or the expansion of the age demographic for whom the vaccine is authorized or approved.
Insurance services provided by CoverEase Insurance Services, LLC and its licensed agents and affiliates. The information contained within these materials are confidential and not to be distributed. Descriptions are general in nature only. Please refer to the terms and conditions of policies offered or purchased. Insurance products are subject to application and underwriting requirements. Pricing depends on a variety of factors including policyholder location. Not all discounts available in all states. Not all products available in all states. Use of and access to this information, site or any of the links contained within this site does not create a relationship between the user and CoverEase. © 2022 CoverEase, Inc. All Rights Reserved.
