"Rather than issuing additional formal guidance, the EEOC has opened the lines of communication with stakeholders through their website and responded more actively to questions about the nuances of their final ADA and GINA wellness program regulations -- particularly on how these rules apply when an employer offers multiple health coverage options or a multi-faceted program.... [R]ulings in two pending cases questioning the validity of wellness programs and a new lawsuit brought by the AARP demonstrate that case law in the wellness arena is still very much in flux and ultimately could impact wellness program design and strategy."