Comment 20 JHU, Georgetown, and NWI Response to Comments 2.20.09
Baum.Beth
Response to comments submitted to the Request for Information on the Genetic Information Nondiscrimination Act issued October 10, 2008 by the Departments of Treasury, Labor, and Health and Human Services As part of an ongoing collaboration funded by The Pew Charitable Trusts, the Genetics and Public Policy Center at Johns Hopkins University, the Georgetown Health Policy Institute, and the National Workrights Institute have analyzed the comments submitted to the recent Genetic Information Nondiscrimination Act (GINA) Request for Information (RFI). We submit this additional analysis to address a number of issues raised in others’ responses to the RFI. 1. Health Risk Assessments, Wellness Programs, and Disease Management Programs Summary: GINA prohibits health insurers from requesting or requiring genetic information, including family history. There is no exception in Title I for wellness programs, health risk assessments (HRAs) used as part of wellness programs, or disease management programs implemented by health insurance issuers for their enrollees. Thus, genetic information including family history may not be collected through HRAs and wellness programs that are part of the employer‐sponsored health plan, nor collected by health insurance issuers prior to enrollment ...