EEOC’s Proposed Wellness Regulations Bring Some Clarity and Some Questions [Employee Benefit Plan Review]

Debra Friedman, a member of Cozen O’Connor’s Labor & Employment Department, discusses the Equal Opportunity Employment Commission’s (EEOC) recently issued notice of proposed rulemaking with respect to employer-sponsored wellness programs, focusing on the interplay between the Americans with Disabilities Act (ADA) and the Affordable Care Act (ACA). The proposed rule would amend the employment provisions of the ADA regulations, as well as EEOC interpretive guidance. She offers advice on how employers can prepare for this potential change in regulation.

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