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White House Takes Steps to Modify Healthcare Rules and Stop CSR Funding (PDF)
Groom Law Group Link to more items from this source
[Guidance Overview]
Oct. 17, 2017

"While the Executive Order hints at the possible paths the DOL might utilize to expand access to [association health plans (AHPs)], there is a host of unanswered questions ... [including] [1] will the AHP be treated as a 'multiple employer welfare arrangement' (MEWA) ... [2] will sole proprietors be allowed to participate in the AHP ... [3] could individual non-employees be permitted to participate in AHPs; and [4] will DOL utilize its existing authority ... to except certain self-funded plans from state regulation if the AHP is determined to constitute a MEWA.... The Executive Order appears likely to result in the Departments pulling back on their existing guidance related to the use of non-integrated HRAs. Depending on how the HRA is treated under any new guidance, the Departments will need to address a series of related questions[.]"

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