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DOL Issues FAQs in Support of 'Pathway 1' Association Health Plans
Mintz [Guidance Overview] June 4, 2019 "Status as a bona fide association is a narrow exception to the general rule that treats associations as a collection of individual (generally, small) employers and not as a single (generally, large) employer. In a state that recognizes Pathway 1, there is no need to seek the DOL's opinion. Often, an association's claim to bona fide association status, backed up by an opinion of counsel, will suffice." |
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