"Despite the ACA's laudable policy goals of promoting affordable health care and transforming America's workers into a healthier and more productive workforce, the EEOC decided to file the Orion and Flambeau suits, and far more surprisingly, the Honeywell suit -- after dragging its feet for 14 years on providing meaningful guidance.... [T]he lack of long-sought EEOC guidance on how to promote participation through reasonable incentives and costs, coupled with concerns stemming from undue litigation risks, may challenge the use of certain financial incentives that could make the use of wellness programs more effective."