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Posted

As of this morning, it appears HHS has removed nearly all of the Section 1557 subregulatory guidance (FAQs and Fact Sheets). Entries still appear in search results on the HHS website (as of noon-ish on Feb. 5), but the content itself is gone.  (Also see the link here to OCR's Section 1557 section -- it's broken.)

Archived copies should generally be available at web.archive.org (although I didn't check for each and every missing page), but it does appear that the current guidance/enforcement may be changing.

Posted

Lois Baker, thank you for your careful attention and the information.

For those BenefitsLink readers who sometimes work with health plans:

With the executive agency’s interpretations changing across the Obama, Trump I, Biden, and Trump II administrations, it might be simpler for health plans’ advisers to read courts’ interpretations of the 2010 Act of Congress.

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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