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EEOC Issues Guidance on New Wellness Notice Mandated for 2017
Thompson Coburn Link to more items from this source
[Guidance Overview]
Jan. 11, 2017

"The [EEOC Q&As] clarify that an employer is not required to provide the [new model notice] if the employer currently provides a notice that informs an employee what information will be collected via the wellness program, who will receive it, how it will be used, and how it will be kept confidential. However, if all of this information is not included in the existing notice or if the existing notice is not easily understood, the employer must provide the new wellness program notice. The Q&As also note that, while a third party provider may provide the notice on behalf of any employer, it is the employer who is ultimately responsible for making sure that employees receive the new notice."

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