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American Benefits Council Comments on Self-Insured Plan Reporting to State All Payer Claims Databases (APCDs)
American Benefits CouncilLink to more items from this source
[Opinion]
June 22, 2021

"[R]equiring employers to master the laws of 50 states and to submit different data sets, at different times, in different formats, for different populations would impose substantial burdens on self-insured plans. These significant costs would ultimately be borne in whole or in part by plan participants ... [We] ask that the Committee report and the subsequent DOL guidance to the states, state clearly and unequivocally that states cannot require self-insured plans to report to state APCDs."

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