Regional Vice President of Sales The Retirement Plan Company
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Bates & Company, Inc.
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AimPoint Pension
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Loan & Distribution Specialist AimPoint Pension
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Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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Compass
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Guidance Clarifying Application of Fair Share Contribution Requirement under Massachusetts Health Care Reform Act
Mintz Levin [Guidance Overview] Aug. 28, 2009
Excerpt: The proposed rules leave much of the current FSC testing structure intact. They do, however, make some important clarifications relating to the employer's burden of proof. While DHCFP did not explain its reasons for making these changes, the changes appear to respond to two particular positions that the DUA is taking on audit -- positions which, in our view at least, appear to lack support. In addition, for the first time the proposed rules expressly recognize that a group health plan may consist of a premium reimbursement arrangement. This client advisory explains the key features of the DHCFP's proposed rules and their likely consequences if adopted.
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