"In March 2010, with the President's support for an incentive-based approach to wellness and a statement of Congress' approval of such an approach to wellness, the [ACA] amended the HIPAA nondiscrimination and wellness provisions to allow employers to provide larger incentives to employees who satisfy requirements of the employer's health promotion and disease prevention (i.e., wellness program). Regulations implementing the HIPAA provision have been issued as well. They include 'bright-line' rules for determining the nature and extent of the incentives an employer may include in its wellness program.... The [EEOC] would effectively make meaningless the ACA and HIPAA provisions and regulations."