"More than one dozen class action lawsuits were filed this year challenging wellness programs that increased group health plan premiums for participants who use tobacco.... [These] lawsuits largely stem from alleged deficiencies in the [reasonable alternative standard (RAS)] requirement or its implementation, including failing to provide the notice of a RAS in all plan materials, communicating misleading information regarding the RAS, failing to provide a RAS altogether, and failing to make the full wellness program reward available to individuals who complete the RAS."  MORE >>