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ERISA Industry Committee Comment Letter to HHS on Proposed Regs for Transitional Reinsurance Fee (PDF)
The ERISA Industry Committee [ERIC] Link to more items from this source
[Opinion]
Dec. 31, 2012
"HHS should defer collection of the $5 billion U.S. Treasury contribution beyond 2016.... The regulation should make clear that States may not collect additional fees from self-insured plans.... [and] should define 'major medical coverage'.... HHS should clarify that the enrollee counting methods exclude plan participants who do not have major medical coverage.... The regulation should provide a 'single life' rule for covered HRAs.... identify a group health plan by reference to the COBRA rules.... [and] permit employers to disaggregate plans that offer both self-insured and insured coverage options to different groups.... The plan aggregation rules should be permissive rather than mandatory, and should apply only to overlapping coverage.... HHS should, in the future, comply with the Administrative Procedure Act by allowing a meaningful comment period."

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