Weekly Health Compliance Briefing

September 9, 2026

While we do our best to provide timely updates, it is possible that the information shared in the newsletter may change after our publication deadline.

Note to Subscribers

 

Due to a restructuring in our digital marketing group, your Weekly Health Compliance Briefing (HCB) may be delayed a day. If you don’t receive your HCB email push on Wednesday in any given week, please look to receive it on Thursday instead. Sorry for any inconvenience this may cause.

Aon Publications

 

FAQ Guidance Issued on Nondiscrimination and Wellness Programs
The Departments of Labor, Treasury, and Health and Human Services (the Departments) issued frequently asked questions (FAQs) Part 74 on nondiscrimination and wellness programs in response to continuing litigation challenging tobacco surcharge designs. The Departments announced enforcement relief for health-contingent wellness programs on whether the “full reward” must be applied retroactively when a participant completes a reasonable alternative standard (RAS) midyear. The FAQs also clarify when plan materials must include RAS language (i.e., materials describing the terms of a health-contingent wellness program must include the disclosure, while materials that only reference the existence of a wellness program generally do not).

The Aon bulletin is available here.