Wellness Programs and the Affordable Care Act (ACA)

 The "trinity" of ACA enforcement (i.e., Departments of Labor, Treasury, and Health and Human Services) issued final regulations relative to wellness programs and rewards, on May 29, 2013. There were no surprises to what we already knew from the law itself.  But reviewing the briefing reminded me that there are two (2) profoundly different types of wellness programs: