"The ADA proposed rules would create an entirely new compliance framework for employers that sponsor wellness programs.... If the proposed rules are finalized in their present form, existing wellness programs may need to be reconfigured to fit within the new parameters.... The GINA proposed rules represent a major shift in policy. Previously, employers could offer significant rewards in exchange for a spouse (or other family member) who completes an HRA. The GINA proposed rules would pare this down to a de minimis reward."