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Does Your Wellness Program Comply with HIPAA Nondiscrimination Regulations? Updated December 15, 2008 (PDF)
Holme Roberts & Owen LLP 
[Guidance Overview] Dec. 18, 2008
3 pages. Excerpt: WHAT SHOULD PLAN SPONSORS DO? As soon as possible, plan sponsors should: Evaluate all group health plans (including medical, dental, vision, and employee assistance programs) and determine if they offer a reward based on a health factor. Use the [checklist in the target document] to determine if the reward complies with the HIPAA nondiscrimination regulations. Contact your health and welfare benefits counsel as to how the HIPAA nondiscrimination regulations apply to your plans and how to address any potential noncompliance issues.
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