I don't think this is as much as a problem with normal kickbacks since the party being directly "harmed" here is an insurance company not getting as good a deal as they could and their whole job is to set prices for policies to account for that. Of course, this could lead to a bigger problem, because insurance companies could account for programs like this in rates, and now you have an arms race where your policy only makes cost sense if you are getting these incentive payments.