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This past summer, Encores Fid Guru Blog published the article Two District Courts Allow Tobacco Surcharge Cases to Advance, Establishing Troubling Precedents for both Tobacco Surcharge Cases and Other ERISA Cases. In this article, we highlighted separate federal district court rulings allowing two tobacco surcharge lawsuits to survive the motion-to-dismiss, and forecasted that these rulings would lead to an increase in the number of similar tobacco surcharge lawsuits being filed

Acknowledging that clinicians may not have adequate time and may not feel comfortable treating tobacco use disorders, simplified models such as AAR (ask, advise, refer to treatment resources) or AAC (ask, advise, connect patients to a quitline via fax, phone, or electronic referral) can be used

Where Have the Confident, Happy Heroes Gone?"

I unfortunately did not make it through the day for the first time in this series

The results

It wasn't unpleasant, but I am not a huge leather fan myself