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American Benefits Council Letter to Tri-Agencies Requesting Extension of Enforcement Discretion Related to Qualifying Payment Amounts (PDF)
American Benefits Council 
[Opinion] Apr. 22, 2024 "[The Council is] writing now to make the tri-agencies aware that [Council] members, including plan sponsors and their service providers, including third party administrators (TPAs) (who do the bulk of the work regarding the QPA calculation), have expressed to us that additional time is needed in order make the QPA-related changes required by TMA III. This is due to the complexity and breadth of the required changes[.]" |
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