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HHS Issues Final Rule on ACA Section 1557 Nondiscrimination Rules, Affecting Certain Employer-Sponsored Plans
ADP [Guidance Overview] May 23, 2016
"There was some concern under the proposed rule that, while an employer ... may not be directly liable for a self-insured plan design ... employers that use a TPA that is subject to the rule would also be effectively subjecting themselves or their plan design to Section 1557. The final rule clarifies that although Section 1557 may apply to the TPA, it does not necessarily mean that Section 1557 extends to the benefits administered by the TPA."
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