As employers wrap up their final plan designs for 2015 and prepare for the beginning of open enrollment, they may want to take another look at their wellness program design. There has been a lot of focus on the ACA wellness rules that the Departments of Labor, Treasury and HHS released earlier this year. But it was the Equal Employee Opportunity Commission (EEOC) that filed a lawsuit last week against a Wisconsin company, claiming that their wellness program design violates the Americans with Disabilities Act. In light of this development, it might be wise for employers to do one last review with ACA and ADA compliance in mind.
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