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Compass
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DOL Finalizes MEP Regs
Ferenczy Benefits Law Center [Guidance Overview] July 31, 2019
"[The final regulation] does not provide any relief for so-called 'Open MEPs' ... [T]he DOL is also requesting considerable input from the practitioner community regarding Open MEPs, as a prelude to considering further regulation.... [T]he Regulation refers often to the possible coordination by associations of their health plan offerings with their retirement programs ... The AHP final regulations were struck down by the D.C. District Court ... in March of this year ... [S]ome of the structure of the Regulation reflects changes meant to resolve some of the elements of the court decision ... [T]he Regulation contains a 'severability' clause[.]"
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