UPDATE (Dec. 7, 2015): The EEOC has extended the comment period on its proposed GINA-wellness rule by 30 days. The new comment deadline is January 28, 2016.
Earlier this month, I had a relatively short post on the proposed rule on wellness incentives and the Genetic Information Nondiscrimination Act issued by the Equal Employment Opportunity Commission. I also promised a more in-depth piece that would be done in coordination with our benefits attorneys.
Hot off the press and just in time for your long Thanksgiving weekend (yeah, right) is the in-depth piece, on which I collaborated with Debbie Hembree in our Birmingham Office and Brian Magargle in our Columbia Office. The latest bulletin compares and contrasts the EEOC's GINA proposal with its proposal issued in April regarding wellness programs and the Americans with Disabilities Act.
But wait! There's more!
Thanks to Debbie and Brian, the new piece also compares and contrasts both EEOC proposals with the wellness requirements under the Health Insurance Portability and Accountability Act, and the relevant provisions of the Affordable Care Act.
What more could you want?
The bulletin that was emailed to our newsletter subscribers yesterday also had a one-page chart that gives you a quick overview of how the EEOC proposals interact with the HIPAA and ACA requirements. If you subscribe to our newsletters, you should already have everything. But if you don't, you won't. The article is up on our website, but the chart is not.
So, for those of you who read our blog but don't get our newsletters, here (again) is the in-depth article. Here is the pdf comparison chart.
Happy Thanksgiving!
- Of Counsel & Chief Legal Editor
Robin also conducts internal investigations and delivers training for HR professionals, managers, and employees on topics such as harassment prevention, disability accommodation, and leave management.
Robin is editor in chief ...
This is Constangy’s flagship law blog, founded in 2010 by Robin Shea, who is chief legal editor and a regular contributor. This nationally recognized blog also features posts from other Constangy attorneys in the areas of immigration, labor relations, and sports law, keeping HR professionals and employers informed about the latest legal trends.

