As stated in the previous post, the limited reward cannot exceed 20% of the cost of employee-only coverage, based on the benefit option in which the participant is enrolled. Therefore, if an employer wanted to offer the same wellness reward to all participants, regardless of benefit option, then the reward must meet the 20% test for each plan.
Combination awards are permitted. For example, perhaps the wellness plan has more than one wellness goal:
Earn 25% of the reward by attending health education lunch & learn meetings
Earn 25% of the reward by lowering blood sugar
Earn 50% of the reward by reducing BMI
When designing a combination wellness reward, avoid having too many requirements in order to qualify for the full 20%. If the program is too difficult, time-consuming or confusing for participants, the wellness plan could fail to meet HIPAA’s reasonableness standard. Just looking at the example I used in this post, I think it would fail the reasonableness standard. Too much to do! I would let participants chose either the blood sugar or the BMI in addition to attendance at the lunch & learns and leave it at that.