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ECFC Comment Letter to CMS and HHS on Proposed Standards for Essential Health Benefits, Actuarial Value, and Accreditation, Including Request for Extension of Comment Period (PDF)
Employers Council on Flexible Compensation [ECFC] 
[Opinion] Dec. 23, 2012
"[G]iven the proposed rule's significant implications, ECFC respectfully requests that the Department provide for at least a 60-day comment period.... Despite working diligently to digest the proposed rule and prepare this response, [the Employers Council on Flexible Compensation] -- along with any number of stakeholders -- could benefit from a longer comment period, which will help ensure that the comments and recommendations received by HHS are well-informed, constructive, and complete."
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