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Election Results Likely to Result in the End of the ACA as We Know It, But Employers and Plan Sponsors Should Stay the Course for Now
Proskauer's ERISA Practice Center
Nov. 10, 2016
"President-elect Trump could issue a directive to agencies to stop all enforcement of regulations currently in effect under the ACA.... Moreover, a significant part of the ACA's enforcement infrastructure is found in sub-regulatory guidance ... meaning that there are opportunities for the new administration to take action without significant procedural hurdles. One could surmise that the days of expansive interpretations of the ACA in sub-regulatory guidance are over and, in some cases, prior sub-regulatory guidance would be reversed."
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