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( 1 ) Where the relevant data suggest that the nonquantitative treatment limitation contributes to material differences in access to mental health and substance use disorder benefits as compared to medical/surgical benefits in a classification, the plan or issuer must take reasonable action, as necessary, to address the material differences to ensure compliance, in operation, with this paragraph (c)(4) and must document the actions that have been or are being taken by the plan or issuer to address material differences in access to mental health or substance use disorder benefits, as compared to medical/surgical benefits, as required by 146.137(c)(5)(iv)

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While big tax hikes or outright sales bans would indeed benefit the black market, gradual price boosts and more strident messaging can bring down smoking rates, Cunningham said