How Wellness Programs Affect Affordability and Minimum Value Calculations

By Linda Rowings

We field a lot of questions from employers about wellness programs and how they comply with PPACA.  Here are two of the most common ones from UBA’s “Frequently Asked Questions (FAQ) About Wellness Programs’ Legal Requirements”:
Q:      How does a wellness program affect affordability calculations?

A:      The proposed regulations provide that when deciding if the employee’s share of the premium is affordable (less than 9.5% of the employee’s safe harbor income), the employer may not consider wellness incentives or surcharges except for a non-smoking incentive. In other words, the premium for non-smokers will be used to determine affordability (even for smokers). Any other type of wellness incentive must be disregarded.

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