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Wrap Plans and PPACA


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I've been looking for some time now for a meaningful discussion addressing the impact of health care reform on wrap documents, specifically whether an employer adopting a wrap plan needs to adopt health care reform related amendments prior to the end of 2010, and whether the wrap plan in and of itself (as opposed to the underlying health plan(s)/insurance contract(s)) is required to make a grandfathering decision (and everything that flows from that decision).

I haven't been able to find much - I'd appreciate any thoughts/insights that anyone has had or determinations made regarding what employers with wrap plans are required to do prior to year end.

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