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ERIC Comment Letter to HHS on Proposed Regs for Nondiscrimination in Health Programs (PDF)
The ERISA Industry Committee [ERIC]Link to more items from this source
Nov. 10, 2015
16 pages. "As interpreted in the Department's proposed regulation, this provision would extend far beyond its statutory boundaries, and would inappropriately encumber the design and day-to-day operation of employer group health plans that do not receive any form of Federal financial assistance.... Employers and the plans they sponsor are already subject to a complex web of Federal statutes and regulation s that prohibit all of these forms of discrimination, and more.... [T]he Department's proposed rule does not adequately reflect the way in which self-funded group health plans are designed and administered. The proposed rule would disrupt the administration of these plans and increase health care costs for employers and employees alike, without adding any additional protection against discrimination."

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