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|Incentivizing (COVID-19) Vaccinations: What Employers Need to Know|
Feb. 15, 2021
"Employers that offer incentives to employees to get vaccinated may be creating group health plans under [ERISA]. In addition, incentivized vaccination programs may need to comply with [HIPAA] ... [G]uidance issued under the Genetic Information Nondiscrimination Act of 2008 (GINA) provides a road map for employers to avoid running afoul of GINA."
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