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The law permits employers to use the wellness plan exception to reward non-smokers because, as a matter of public policy, lawmakers have decided that employers should be able to impose higher costs on tobacco users because they account for a disproportionate share of overall claims which in turn leads to higher premiums for all participants in employer-sponsored group health plans

Offers practical considerations for implementing a tobacco surcharge

[9] In 2017, the focus was "A threat to development"

But in order to accomplish this, tobacco companies need access to consumer purchasing trends

From 1965 to 2014, about 6.4 million women died from smoking-attributable disease