GLP-1 medications, originally developed for diabetes and now widely used for weight management, are rapidly becoming a major cost concern for employer health plans. Annual costs per user often exceed $10,000, and demand is rising, especially with new forms like daily pills recently approved by the FDA. Employers are now facing tough decisions about how to manage these costs while supporting employee health and staying compliant with the law.

How Employers Are Responding

Many employers are rethinking their approach to GLP-1 coverage. Some are narrowing coverage to only those with certain medical conditions (like type 2 diabetes or obesity above a specific BMI), while others are considering dropping coverage altogether. Generally, employer health plans are not legally required to cover GLP-1s, but changes in coverage can create legal and employee relations risks — especially if changes are not properly documented, communicated clearly, or applied consistently.

Key Considerations for Coverage Decisions:

  • If you limit or remove GLP-1 coverage, make sure the criteria are clear, consistently applied, and well-documented.
  • Communicate any changes to employees in advance and through multiple channels (plan documents, benefit guides, enrollment materials).
  • Be prepared to explain the rationale for your decision, including cost, clinical guidance, and fairness.

Alternative Ways to Support Employees

Employers looking for middle-ground solutions may consider:

  • Flexible Spending Accounts (FSAs) and Health Reimbursement Arrangements (HRAs): These tax-advantaged accounts can help employees pay for GLP-1 medications, even if the main health plan doesn’t cover them. However, annual limits mean they may not cover the full cost.
  • Direct-to-Consumer Options: Some employees may access GLP-1s through telehealth platforms or manufacturer programs at lower out-of-pocket costs, outside of employer plans.
  • Weight Management Programs: Partnering with vendors that offer nutrition, coaching, and lifestyle support can provide alternatives to medication-based solutions.

Legal and Compliance Risks

Any change to GLP-1 coverage should be handled carefully to avoid legal pitfalls:

  • Update plan documents to reflect changes.
  • Provide timely notice to employees.
  • Apply rules consistently to avoid discrimination claims.
  • Keep records of your decision-making process, including cost data and input from advisors.

Inconsistent administration or informal exceptions can undermine your plan’s legal defensibility and employee trust.

Bottom Line

GLP-1 medications present new challenges for employer health plans. There’s no one-size-fits-all answer, but clear communication, consistent application, and careful documentation are essential. Consult with benefits counsel to ensure compliance and minimize risk.

If you have questions about GLP-1 coverage or want to discuss your options, Akerman’s Employee Benefits team is here to help.