Migliaccio & Rathod LLP is investigating whether Chemours administers its employee wellness program in compliance with ERISA, the ADA, and other applicable federal laws governing employer wellness programs.
Publicly available 2026 benefits materials indicate that Chemours allows employees to reduce their health insurance costs by approximately $1,380 annually through completion of the company’s biometric screening program. According to publicly available materials, the program operates through a $115 monthly payroll credit, creating a substantial financial incentive for employees to complete the required screening. The materials further indicate that employees must complete biometric screening within specified deadlines to preserve the premium credit.
Because the financial consequences of participating—or failing to participate—are significant, this investigation seeks to determine whether Chemours provides employees with all reasonable alternative standards, required notices, accommodations, and refund procedures required under applicable federal law.
What Employees Report
Employees report:
- Completing biometric screenings to receive monthly payroll credits.
- Losing substantial premium credits after missing annual screening deadlines.
- Receiving limited information regarding reasonable alternative standards.
- Uncertainty regarding physician-directed alternatives or accommodations.
- Questions regarding whether retroactive payroll credits are available after completing an approved alternative.
- Paying substantially higher health insurance premiums because of the wellness program.
Why Employees Should Be Concerned
A wellness incentive worth approximately $1,380 annually represents a significant financial difference for many employees. Federal wellness program regulations generally require that employees who do not complete an initial biometric screening have a meaningful opportunity to earn the full reward through a reasonable alternative standard where applicable.
Employees who complete an approved alternative after the initial deadline may also have questions regarding whether premium credits should be applied retroactively or prospectively. Because payroll deductions are standardized, any improper administration may affect large numbers of employees in a similar manner.
This investigation seeks to determine whether Chemours properly administered its biometric screening program and whether employees were improperly denied premium credits or wellness incentives.
Potential Claims May Include
- ERISA Violations
- ADA Wellness Program Violations
- Failure to Provide a Reasonable Alternative Standard
- Breach of Fiduciary Duty
- Improper Administration of Employee Benefits
- Recovery of Improperly Withheld Premium Credits
- Declaratory and Injunctive Relief
Signs You May Be Affected
You may be affected if:
- You participated in Chemours’ employee health plan.
- You were eligible for the biometric screening premium credit.
- You lost all or part of the annual payroll credit.
- You requested a reasonable alternative standard or accommodation.
- You completed a wellness requirement after the stated deadline.
- You still possess payroll records, enrollment materials, wellness communications, or benefits documents.
If you believe you encountered these issues, we would like to hear from you. Please complete the contact form on this page, send us an email at [email protected], or give us a call at (202) 470-3520.