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Group Health Plan Audit Requirement: Whom Do You Trust?
Golan Christie Taglia Link to more items from this source
[Guidance Overview]
Sept. 28, 2017
"If employee contributions are used for any purpose other than paying group health or HMO premiums, then benefits are not deemed to be paid solely from the employer's general assets -- and the audit requirement would apply.... [I]t seems clear that the audit requirement does not turn entirely on the question of whether or not the plan is funded through a trust. But note Q&A 18 published by the American Institute of Certified Public Accountants which states that relief from the audit requirement for contributory self-funded welfare plans with more than 100 participants is based on whether or not the plan is funded through a trust[.]"

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