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|EEOC Proposed GINA Rule on Wellness Program Incentives Brings Progress But Also Perpetuates Errors|
Seyfarth Shaw LLP
Nov. 13, 2015
"[T]he EEOC continues to assert that it has the authority to define what a 'reasonably designed' wellness program is.... Introducing a 'similar' definition means that the EEOC intends to adopt a different standard than the one previously adopted by Congress in the ACA or the Departments of Labor, Treasury and HHS in the Tri-Agency Regulations. Moreover, by importing the 'reasonable design' requirement from 'health-contingent wellness program,' the GINA Proposed Rule (again as in the ADA Proposed Rule) imputes the burdens previously associated only with health-contingent wellness programs to all wellness programs, which exceeds what is required under the ACA and the Tri-Agency Regulations."
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