Tips for Employers with Mid-Year Plans Post AARP v. EEOC

Many employers with mid-year plans (i.e., plans that start on July 1 each year and end on June 30th of the next year) may be wondering what to do about their wellness program incentives for the 2018-19 plan year. The AARP v. EEOC case has confused a lot of people in the workplace wellness industry, and employers with mid-year plans may be the first group to really grapple with the uncertainty that lies ahead. As noted in a previous blog post, the District Court for the District of Columbia issued an opinion in August 2017 vacated the incentive limits of 30% of the total cost of self-only coverage under the Americans with Disabilities Act (ADA) and the Genetic Information Nondiscrimination Act (GINA). Read More