In many respects, employers are well positioned to take a leading role in helping create a culture of health. Employers have access to many programs that could be beneficial to their employees’ health. The potential for financial gains related to health improvement may motivate employers to offer these programs, and if the gains are realized, they may help finance the programs. At the same time, employers’ involvement in such programs may create substantial risks. Enthusiasm about the financial and health gains that wellness programs might yield coexists with concerns about health costs shouldered by employees, the possibility of employment discrimination, and the potential for employers’ invasion of employees’ privacy. A fragmented regulatory regime, including a recently issued final rule under the Americans with Disabilities Act, has been created to address these concerns. Whether the regime strikes the right balance between wellness program benefits and risks remains to be determined.