With little time to spare before employers finalize their plan
designs for 2014, we now have the final rules for wellness
programs. The Agencies officially released the final rules on June
3, 2013, which apply to group health plans for plan years beginning
on or after January 1, 2014 (even if the plan is grandfathered
under the Affordable Care Act).
The Agencies re-designed, some would say dramatically re-designed,
the final rules from what was proposed late last year. Under the
final rules, wellness programs are divided and sub-divided into
three general categories (as explained below). The Agencies even
say that there may be wellness programs hiding within other
wellness programs – requiring employers and plan sponsors to
examine the rules at even a more granular level than ever before.
With all the differentiation in wellness programs and the
hyper-analysis that is now required, all of this leads employers
and plan sponsors to what is now becoming a familiar tune
