Monday, August 28, 2017

Federal District Court Asks EEOC to Reconsider its Wellness Regulations

From the Desk of Larry Gudzien 


On August 22,  the U.S.  Federal District Court for the District of Columbia ordered the Equal Employment Opportunity Commission (EEOC) to reconsider its final regulations in regard to the size of the incentive an employer may offer to participate in wellness program without violating the Americans with Disabilities Act (ADA) or the Genetic Information Nondiscrimination Act (GINA).


EEOC had published wellness program regulations in May 2016.  These regulations were similar to the HIPAA non-discrimination rules but differed in significant respects that made compliance difficult for employers. 

In October 2106, American Association for Retired People (AARP) sued the EEOC alleging that the size of the permissible reward (30% of the cost of single coverage) was too large to be considered voluntary and was in violation of both the ADA and GINA.

The court agreed with the AARP and held that the administrative record did not adequately support the EEOC's regulations as to the size permissible reward. The court felt that the EEOC did not explain their  reasoning for determining the size of the reward.  The Court then ordered the EEOC to reconsider its regulations.

Despite its decision, the court declined to vacate the regulations.  The status quo will remain in effect pending the EEOC's review. 

For a copy of the court decision (AARP v. EEOC, no. 16-2213 2017 BL 293605 (D.D.C. August 22, 2017)), click on the link below:

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