"[The DOL] could fairly quickly expand access to 'single plan' AHPs through informal interpretations of ERISA ... It would be another matter entirely should the [DOL] seek to expand AHPs to cover collections of self-employed individuals with no common law employees. This would require a change to an existing final regulation ... [A]ny attempt to enable groups of unrelated self-employed individuals with no common law employees to participate in an AHP would require publication of a proposed rule with a notice period and opportunity for public comment."  MORE >>