"Because HRA incentives are pulled under the ADA's ceiling, there will be less room remaining to accommodate health-contingent incentives, such as premium discounts tied to cholesterol levels.... [T]he proposed rule effectively represents a compromise between those who oppose incentives and those who would like to take full advantage of incentives permitted under the ACA.... In light of recent litigation, however, it is unclear how much influence this compromise will have in the long term. What might undermine the compromise? The ADA itself."  MORE >>