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Comment Letter by the ERISA Working Group of the National Association of Insurance Commissioners, to NAIC ERISA Working Group on Draft Guideline Amendments to the Stop Loss Insurance Model Act (PDF)
National Association of Insurance Commissioners - ERISA Working Group 
[Opinion] Aug. 7, 2012
Comments on proposed updates to stop loss model provisions and their effect on self-insurance, particularly for small employers, in light of ACA requirements, submitted by AHIP; Blue Cross Blue Shield; Chambers of Commerce from Illinois, Pennsylvania, Texas and California; Cigna; Protect Health Care Choice Coalition; The Council of Insurance Agents & Brokers; HCC Life Insurance Company; Self-Insurance Institute of America, Inc.; American Insurance Association; and consumer representatives.
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