Letter on ADA Employer Wellness Programs

We are pleased to submit these comments on behalf of the College and University Professional Association for Human Resources, the International Public Management Association for Human Resources, the National Public Employer Labor Relations Association, the Associated Builders and Contractors, the National Retail Federation, and the Retail Industry Leaders Association in response to the Equal Employment Opportunity Commission’s (EEOC’s or Commission’s) proposed amendments to the regulations implementing Title I of the Americans with Disabilities Act (ADA) as published in the Federal Register on April 20, 2015.1 The proposal addresses the use of employer wellness programs and the extent to which the use of incentives in conjunction with such programs may violate the ADA.