Migliaccio & Rathod LLP is investigating whether JPMorgan Chase administers its employee wellness program in compliance with the Employee Retirement Income Security Act (“ERISA”), the Americans with Disabilities Act (“ADA”), and other applicable federal laws governing employer wellness programs.
Publicly available 2025–2026 benefits materials indicate that JPMorgan Chase offers eligible medical-plan participants the opportunity to earn up to $700 annually through its wellness program. According to those materials, certain incentives are tied to biometric “healthy outcomes,” including body mass index (BMI) and blood pressure targets. Outcome-based wellness programs are generally permitted under federal law, but they ordinarily must provide every participant who does not initially satisfy the health standard with a reasonable alternative standard that allows the participant to earn the full reward.
This investigation seeks to determine whether JPMorgan Chase’s wellness program provides employees with all protections required under applicable federal law, including meaningful reasonable alternative standards, appropriate notices, and full access to available incentives.
What Employees Report
Employees report:
- Completing biometric screenings or wellness activities to qualify for premium incentives.
- Being informed that certain rewards depend upon meeting biometric targets such as BMI or blood pressure.
- Receiving limited information regarding reasonable alternative standards if they did not satisfy the initial health metrics.
- Uncertainty regarding physician-directed alternatives or medical waivers.
- Questions about whether all available wellness rewards could still be earned after completing an alternative program.
- Paying higher health insurance premiums or losing wellness incentives after failing to satisfy biometric targets.
Why Employees Should Be Concerned
Federal regulations generally distinguish between wellness programs that merely require participation and programs that reward employees for achieving particular health outcomes. When incentives depend upon meeting biometric standards such as BMI or blood pressure, employers generally must offer participants who do not initially satisfy those standards a reasonable alternative that allows them to earn the full reward.
Employees who are not adequately informed of available alternatives—or who are unable to earn the complete incentive despite participating in an approved alternative—may lose hundreds of dollars in annual wellness rewards or pay higher health insurance premiums than federal law permits.
This investigation seeks to determine whether JPMorgan Chase properly administered its biometric wellness program and whether affected employees may be entitled to recover improperly withheld wellness incentives or premium differentials.
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 Wellness Incentives
- Declaratory and Injunctive Relief
Signs You May Be Affected
You may be affected if:
- You participated in JPMorgan Chase’s employee medical plan.
- You completed biometric screenings or health assessments.
- You were required to meet BMI, blood pressure, or other biometric targets to receive wellness incentives.
- You were not clearly informed about reasonable alternative standards or physician accommodations.
- You lost wellness rewards or paid higher premiums after failing to satisfy biometric targets.
- You still possess enrollment materials, payroll records, 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.