Do ACA rules apply to nonfinancial rewards for wellness program participation?


Your group health plan provides gift cards and sports gear as incentives to participants who adhere to a wellness program. Are these nonfinancial incentives subject to the wellness program regulations under the Patient Protection and Affordable Care Act (ACA)?


Yes. If a group health plan provides a “reward” based on an individual satisfying a standard that is related to a health factor, the wellness program is subject to the wellness regulations.

As provided in the regulations, a reward may be financial or nonfinancial (or in-kind). More specifically, the regulations provide that reference to an individual obtaining a reward includes both “obtaining a reward (such as a discount or rebate of a premium or contribution, a waiver of all or part of a cost-sharing mechanism (such as a deductible, copayment, or coinsurance), an additional benefit, or any financial or other incentive) and avoiding a penalty (such as the absence of a surcharge or other financial or nonfinancial disincentives).”

Source: FAQs about Affordable Care Act Implementation (Part XXIX) and Mental Health Parity Implementation, Q11, October 23, 2015;

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