The Equal Employment Opportunity Commission (“EEOC”) has issued two final rules addressing employer-sponsored wellness programs’ compliance with Title I of the Americans with Disabilities Act (“ADA”) and Title II of the Genetic Information Nondiscrimination Act (“GINA”). Both rules will become effective for health insurance plan years beginning on or after January 1, 2017 and
wellness programs
EEOC Releases Proposed Rule on Employee Wellness Plans
By Katharine Parker, Laura Fant, Stacy Barrow & Tzvia Feiertag on
Yesterday, the Equal Employment Opportunity Commission (EEOC) released a long awaited proposed rule on employee wellness programs. The rule is designed to help companies structure such programs to meet their obligations under the Americans with Disabilities Act (ADA).
The ADA prohibits medical exams that are not job related and consistent with business necessity but…
EEOC Takes First Step Toward Issuing Rules on Employer-Sponsored Wellness Plans
By Katharine Parker & Laura Fant on
On March 20, 2015, the Equal Employment Opportunity Commission (“EEOC”) announced its submission of a notice of proposed rulemaking (“NPRM”) on employer-sponsored wellness plans to the White House Office of Management and Budget (“OMB”) for review. This is the first step toward official EEOC regulations on the subject of wellness plans. Assuming the OMB provides…