03 Jul Understanding the ACA: Incentives Impacting Benefit Plan Design

Under the ACA wellness regulations, employers now have the option of adjusting the benefit plan design (such as adjusting deductibles, providing an HRA deposit or moving to a different schedule of benefits) as participants achieve healthy outcomes, instead of adjusting employee premium contributions based on wellness results.

Be aware that offering these types of incentives add administrative complexity versus adjusting premium contributions.

Benefit Plan Design Examples:

    • Only the portion tied to tobacco use can be factored into the affordability and minimum value calculations.
    • The COBRA actuarial value for the different incentives must be calculated to determine that the incentives are within the 30% / 50% permitted differential.
    • Summary of Benefits Coverage (SBC) amendments are required.
    • Wellness incentives impacting benefit plan design must be offered to COBRA participants.
    • External review of adverse appeals decisions is required.