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Kilpatrick Townsend Comment Letter to HHS on the Application of the Reinsurance Fee to Employer Group Health Plans
Kilpatrick Townsend 
[Opinion] Oct. 7, 2012
"The definition of Group Health Plan should specifically exclude employee assistance programs, disease management programs and wellness programs.... 'retiree-only' plans ... [and] health flexible spending arrangements.... The calculation of Reinsurance Contribution Enrollees [RCEs] should account for the various methods that group health plans use to determine covered employees and their covered dependents.... [T]he definition of RCE should specifically exclude individuals who are Medicare-eligible.... Individuals who are not residents of the United States should be excluded from determining the number of [RCEs]."
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