Best to take it out of the economy then. Or I could see a DNI action pool category based on Logic/3, Logic/2, or granted by ware.
Introducing a new action type (free) or a DNI action pool would just increase the overall complexity of the rules, and not needed since it's already handed in a simpler way by the refund.
Taking it out of the action economy is not a good option either, since it would allow you to "do the thing", even if you suffer from a status that prevent you from taking any actions. At the very least, it would be a whole new issue to debate in lengths.
The current rule seems to work fine.