Premium discounts and surcharges on employee contributions to employer-sponsored health plans based on COVID-19 vaccination status has become a hot topic. On October 4, 2021, the Departments of Labor, Health and Human Services, and Treasury issued FAQs regarding the application of the HIPAA wellness program rules to vaccine-related premium surcharges and discounts. HIPAA prohibits group health plans from discriminating against participants with respect to eligibility, premiums or contributions based on any “health factor”. However, the… Continue Reading Vaccine Incentives and Surcharges in Health Plans: The HIPAA Police Weigh In