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More on Transitional Reinsurance Sticker Shock
Benefits Bryan Cave 
[Guidance Overview] Dec. 20, 2012 "Retiree plans are subject to the fee. However, CMS proposed that all plans (retiree or not) only need to pay for enrollees for which the plan is primary to Medicare as, of course, most are. No reinsurance fee is due with respect to participants for whom Medicare is primary. The good news is that the IRS has confirmed already that the fee is deductible, and it reports that the DOL has advised the IRS that the fee is a permissible plan expense." MORE >> |
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