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In Sweden, many people get their nicotine from sucking smoke-free tobacco called "snus." Research there has put rates of lung cancer, heart disease and other smoking-related illness among the lowest in Europe

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Plaintiffs have argued that because ERISA (and the implementing wellness program regulation) requires that employers provide participants who complete a wellness programs alternative standard with the wellness programs full reward, participants who complete a tobacco cessation course should be reimbursed all premium surcharge amounts paid for the full plan year

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An application of neoclassical theory revealed the positive economic results of the deal, while an institutional application viewed the agreement in light of multiple factors and left questions to be asked