Reminder: Rewards for Life and Certain Other Wellness Programs Must Comply with EEOC Regulations

Equal Employment Opportunity Commission’s (EEOC) final regulations issued last year under Title I of the Americans with Disabilities Act (ADA) and under Title II of the Genetic Information Nondiscrimination Act (GINA) for employers that offer wellness programs that provide incentives for collecting certain health information went into effect as of January 1, 2017. These regulations apply to the NRECA Medical Plan’s Rewards for Life^® program, as well as to other employer-sponsored wellness programs—whether or not they are part of a group health plan—that provide incentives for participation in a health risk assessment (e.g., a health survey) or medical exams (e.g., biometric screenings).

EEOC notice
As one of the requirements, employers must provide a notice that explains what health information the wellness program will collect, how it will be used, who will receive it and how it will be protected, as well as related incentives and wellness activities and health outcomes. Cooperatives in NRECA’s Rewards for Life Program should provide this notice to anyone eligible to participate in the program. A sample EEOC notice is available on the Employee Benefits website as well as on the EEOC website.

More resources
For more on the EEOC requirements, refer to the flier made available last fall to help co-ops understand how the regulations may affect their wellness programs. You also can reread the article in Benefits Bulletin on page 8 of the September 2016 issue.

If you have questions about how the EEOC regulations affect your wellness program, contact the wellness team at wellnessprogram@nreca.coop.