This year is off to a fast start and plan sponsors might find their heads spinning as they try to keep track of rapidly developing employee benefits legislation and guidance. We periodically consolidate key newsletters and blog posts to help our readers stay organized and catch up on items they might have missed. Below, please […]
For years we have been trying to understand how the EEOC regulates wellness programs. Although we still do not have a complete picture, we are getting closer with the EEOC’s new Notices of Proposed Rulemaking on wellness programs under the Americans with Disabilities Act (“ADA”) and the Genetic Information Nondiscrimination Act (“GINA”). This blog summarizes […]
On May 16, 2016, the EEOC issued final rules that explain how the Americans with Disabilities Act (“ADA”) applies to employer sponsored wellness programs. Although some may welcome the guidance, others may be frustrated because the rules are somewhat inconsistent with the rules under HIPAA, inconsistent with the court decisions under Seff v. Broward County, […]
As explained in our April 21, 2015 and May 9, 2015 blog posts, wellness programs that are part of a group health plan are subject to the HIPAA nondiscrimination rules, and other state and federal laws including, but not limited to the ADA, Title VII of the Civil Rights Act, and GINA. Navigating the regulatory […]
