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2 Division of Pulmonary, Critical Care, and Sleep Medicine, University of Miami, Miami, FL, USA

The plan sponsor argued that it acted merely as a settlor in setting the terms of its wellness program and imposing the surcharge on any participants who failed to comply with those terms. Not so, according to the district court

Second, the study was conducted at a single center and included volunteers attending an outpatient clinic, which may limit generalizability and introduce volunteer bias, as participants who agreed to take part could differ systematically from those who declined (e.g