I would like to see added clarification to the Wellness Rules related to the health-contingent wellness programs to make it clear that the full incentive being offered must be provided by the end of the plan year (or within 30 days following the plan year) in which the incentive applies. I would also like added examples that clearly show that a reasonable alternative must be supplied to all participants in a health plan regardless of whether they have an underling medical condition that may have caused the failure to meet a specific health factor being measured under the health-contingent wellness program (i.e., someone overweight with a BMI of 40 may not yet have a medical condition, but they should have the opportunity to participate and achieve an alternative and still receive the “full incentive” in the plan year to prevent discrimination.
Comment on FR Doc # 2012-28361
This is comment on Proposed Rule
Incentives for Nondiscriminatory Wellness Programs in Group Health Plans
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