May Our Self-Insured Health Plan Limit Eligibility to Employees Vaccinated Against COVID-19?
ThomsonReuters
MARCH 3, 2022
The following groups may be treated as distinct groups of “similarly situated” individuals for purposes of the HIPAA nondiscrimination rules: (1) groups of participants based on a bona fide employment-based classification, such as length of service or full-time vs. part-time status; (2) participants as a separate group from beneficiaries (e.g.,
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