New Interim Final Regulation on Genetic Information Nondiscrimination Act

The Genetic Information Nondiscrimination Act of 2008 (GINA), signed into law on May 21, 2008, prohibits group health plans, health insurers, and employers from discriminating against individuals on the basis of their genetic information.  Last week, the agencies published interim final regulations implementing Title I of GINA.  The new regulations include a number of provisions that will be of interest to health plans and plan sponsors, the most significant of which we discuss in the attached memorandum.