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Key Changes to Rules Implementing ACA Nondiscrimination Provisions
Dickinson Wright PLLC Link to more items from this source
[Guidance Overview]
July 10, 2020

"The Final Rule makes clear that health insurance companies are not considered to be principally engaged in the provision of healthcare solely because they sell health insurance, if not doing so through one of the marketplaces. Due to this change, many health insurers will likely argue that when the rule changes take effect, Section 1557 no longer applies to them, or if it does, only to a small portion of its program. Benefits administrators may or may not be able to make a similar argument."

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