Can we refuse health insurance to an employee who refuses to participate in a health risk assessment?

The Americans with Disabilities Act (ADA) says that health and disability-related inquiries and employee medical examinations must be “completely voluntary” unless they are specifically job-related and consistent with business necessity. An employee’s HRA participation is not considered to be voluntary if its completion is required for an employee to be eligible for an employer’s health plan or to receive the employer contribution, so employers should not deny an employee access to the health plan for refusal to participate.