"The core problem is that the line between the 'group health plan' and the employer/plan sponsor is a legal fiction. HHS has established a regulatory framework, covering virtually every employer that provides any kind of health benefits to its employees, which is based on the idea that there is a distinction between this 'group health plan' and the 'plan sponsor' of that health plan.... So, HHS has created a complicated set of regulatory provisions based on a legal fiction. Therefore, there has always been real confusion about even these core rules."  MORE >>