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Employers Council on Flexible Compensation Comment Letter to EBSA on Proposed Amendments to Excepted Benefits Regs (PDF)
Employers Council on Flexible Compensation [ECFC] 
[Opinion] Feb. 28, 2014
Topics include: Clarification of Application of Excepted Benefits Rule to Stand-Alone Self-Funded Dental or Vision Only Plans; Availability of Health FSAs to Employees without Access to Employer-Provided Health Coverage; Technical Clarification for Proposed Limited Scope Wraparound Excepted Benefit; and Application of Excepted Benefits Rule to Wellness Programs.
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