"While wellness programs are not required to be accredited or evidence-based, the guidance was accompanied by the release of a study on workplace wellness programs by Rand Corporation and the FAQs referenced standards and practices on evidence based clinical standards in two government studies ... as methods of increasing the likelihood of wellness program success. These are references that may become more important as wellness programs are considered under other applicable laws because compliance with ACA is only one aspect of being a wellness program that is permissible."