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District Court Trumps DOL Association Health Plan Rule (PDF)
Holifleld, Janich & Ferrera Link to more items from this source
Apr. 2, 2019
"[T]he court ruled that DOL unreasonably 'relaxed' two of the three criteria, the 'purpose' test and the 'commonality of interest' test, which were historically used to restrict when an association could establish a bona fide association for purposes of sponsoring a single large group health plan.... [S]tates have been reviewing those laws that restrict the definition of association plans to conform their state laws with DOL's Final Rule. The district court decision likely will disrupt that process." [State of New York v. U.S. Department of Labor, No. 18-1747 (D.D.C. Mar. 28, 2019)]

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