"The IFR allows a fully-insured group health plan to enter into a written agreement with an insurance issuer under which the issuer agrees to provide the report to the Departments and accepts liability for failure to do so.... [S]ponsors of self-funded group health plans may enter into similar agreements with other entities ... [U]ltimate liability for the reporting will remain with a plan sponsor of a self-funded plan regardless of the agreement."  MORE >>