Guide for Considering COVID Vaccination Incentives for Employees
It has become clear that employers have a positive role to play in encouraging and supporting their employees getting the COVID vaccine. Employers are considering offering incentives to employees for receiving the COVID vaccination—but there are a few factors to consider. We’ve put together a brief list of questions, answers, and references, taken from publicly available postings, to help you make a decision about a COVID vaccination incentive program for your organization. If offering an incentive is right for your organization, we believe we can help the incentives be an immediate, secure, and cost effective part of your program.

 

All answers provided are purely meant as guidance. Make sure to consult legal counsel before creating a COVID vaccination incentive program. Tango Card does not provide legal advice.

 

Contents

What types of COVID vaccination incentives can I offer to my employees?
What are the risks of offering a COVID vaccination incentive to my employees?
What value of incentives can I offer for COVID vaccination?
How do I safely disburse COVID vaccination incentives?
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What types of COVID vaccination incentives can I offer to my employees?

In recent news, several companies1 have shared that they are offering incentives, such as:

  • Paid time off (PTO) for all workers
  • PTO after receiving the vaccine
  • Compensation for costs associated with the vaccine
  • A modest incentive, such as a $25-or-less gift card
  • A larger incentive for employees who get the vaccine—we’ve seen $100-$150

This list covers a few of the more widely discussed incentives. Any of these incentives could be part of a more comprehensive strategy aimed at getting all willing employees to get vaccinated. Please read on for guidance on potential risks of various COVID vaccine incentives.

Our customers use digital gift cards to deliver incentives for a broad range of employee reward and wellness programs. In the case of incentives for a COVID vaccine, Reward Link gives an immediate, secure, an enjoyable incentive as part of a comprehensive vaccine program.

What are the risks associated with offering a COVID vaccination incentive?

There are various risks associated with offering vaccination incentives. For a weighted list of these risks, we encourage you to read, Charting The Risk Associated With Common Workplace COVID-19 Vaccine Incentive Programs2.

There are several laws and a proposed regulation to consider when formulating an incentive program for COVID vaccination. When choosing incentives for voluntary vaccination, we encourage you to consider the Americans with Disabilities Act (ADA) and the Civil Rights Act, at a minimum, which are enforced by the Equal Employment Opportunity Commission (EEOC).

The ADA generally permits employer wellness programs to make medical inquiries if the program is voluntary. These inquiries commonly include confirming an employee’s physical or, in the case of a COVID vaccination program, confirming a vaccination has been administered by a third party3.

What value of incentives can I offer for COVID vaccination?

Currently, it’s possible to offer a significant incentive for voluntary wellness programs. For example, we’re familiar with generous $100–$150 incentives for employees who complete an annual physical. More specifically, the EEOC regulations “permit an incentive of up to 30% of the cost of self-only coverage under the employer’s health plan.”

However, as of January 7, 2021, the EEOC has new proposed regulations around voluntary wellness programs. One of the new proposed requirements to be aware of is that the size of an incentive would be limited to one of de minimis value. In gift card terms, we believe this means a value of $25 or under.

It’s possible for these proposed regulations to be frozen by the new administration. It’s also likely that broad-based rollout of the COVID vaccine will take place before the EEOC’s proposed rule becomes law.

For an expanded review of the points raised above and a review of the applicable laws, accommodations, and their implications for COVID vaccine incentives, please read, EEOC’s New ADA Regulations Could Complicate Employer Plans’ Efforts to Offer Incentives for Getting the COVID Vaccine as Part of a Wellness Program4.

How can I safely disburse COVID vaccination incentives?

When it comes to disbursing wellness incentives of any kind, HIPAA rules apply. This makes it important to work with a third-party vendor to manage employee information and an incentive solution that limits sharing of personal information.

At Tango Card, we’re able to work with wellness programs because we only require a small amount of information to deliver digital gift cards. If you’re planning to move forward with a strategy for vaccinations that includes incentives, Tango Card can help you deliver secure, immediate, and cost-effective incentives to your employees.

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About Tango Card

We make it easy to put great reward choices in the hands of your employees and customers. We provide simple technology to help you send, track, and manage rewards and incentives for your business.