Ashley Gillihan and Johann Lee presented this teleseminar for BNA. On October 1, 2009, the IRS, DOL and HHS jointly released an advance copy of interim final regulations on the Genetic Information Nondiscrimination Act (GINA). The interim final regulations (“Regulations”) clarify several key aspects of GINA, including but not limited to, the application of GINA to health risk assessments (HRAs).
GINA will have a significant impact on HRAs. Under no circumstances may HRAs request genetic information prior to enrollment in the plan and no rewards (or penalties) may be offered in conjunction with an HRA that asks for genetic information - even if the request is made after enrollment has occurred. GINA’s group health plan related provisions are effective for plan years beginning on or after May 21, 2009. For most plans, GINA’s effective date for calendar year plans is January 1, 2010. Ashley and Johann addressed these topics.
- What is GINA?
- What is "Genetic Information"?
- What are GINA's rules regarding a health plan's request for Genetic Information?
- What is the impact of GINA on HRAs? More specifically, what information can be requested as part of an HRA after GINA?
October 22, 2009
2:00pm - 3:30pm EDT