On-site clinics utilized in conjunction with a group health plan are becoming an increasingly common method to help employers address the rising cost of health care. The issues in implementing an on-site clinic may seem obvious: Finding a service provider; installing an appropriate facility; and addressing employee access during work hours. However, there are less obvious but equally important compliance concerns that arise when an on-site clinic is implemented. Such clinics maintained on an employer’s premises for “treatment of minor injuries or illness or rendering first aid in case of an accident during working hours” are exempt from the reporting and disclosure requirements of ERISA and other federal mandates such as COBRA. However, to the extent that employer-provided on-site clinics provide services beyond treatment for minor injuries and first aid, they are a means of providing medical care, and the requirements of federal law are important considerations for employers to address in adopting on-site clinic benefits.
ERISA
