Thanks for that link, Eli. This is exactly the type of context I was looking for. It woulds like there is a regulatory hurdle here with significant potential liability if the program were to get challenged as not meeting those requirements both on the actual program design and on the documentation.
It looks like certain wellness programs that are allowed, but there are limits on what you can do if you make it outcome-contingent. https://www.dol.gov/sites/dolgov/files/ebsa/about-ebsa/our-activities/resource-center/publications/caghipaaandaca.pdf
Thanks for that link, Eli. This is exactly the type of context I was looking for. It woulds like there is a regulatory hurdle here with significant potential liability if the program were to get challenged as not meeting those requirements both on the actual program design and on the documentation.