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Proposed Contraceptive Compromise Rule Released
Bryan Cave LLP via Lexology; registration required 
[Guidance Overview] Feb. 5, 2013 "[T]he Departments did not address potential ERISA issues that this structure could implicate. Remember, the whole construct is that the employer is not arranging for, paying for, or otherwise providing the coverage. So is this individual coverage or employer coverage (or neither)? Are Forms 5500 required if more than 100 individuals select the separate contraceptive coverage? Who would be responsible for the preparation of those forms and SPDs?" MORE >> |
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