Where is this going (what can employers do to encourage HRAs legally)?

Apparently, health risk assessments can only be voluntary--not mandatory for coverage--so no stick. Also, beware if you dangle a carrot. While EEOC previously allowed a safe harbor if the carrot was no more than 20% of the value of the coverage. The EEOC has withdrawn that 20% safe harbor. So now even a baby carrot might get you crosswise with the EEOC.

Maybe what is going on is simply this: Employers are bad. Therefore they should just shut up, take their medicine and pay for health coverage to employees no matter how the employees' habits--lifestyle or consumer ones--drive that cost up for the employers.

BTW, metaphors are best served shaken, not stirred.

They can use programs which have been carefully planned and properly evaluated instead of buying either hype or buying because of name and references.