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Comment Letter by the ERISA Working Group of the National Association of Insurance Commissioners, to NAIC ERISA Working Group on Draft Guideline Amendments to the Stop Loss Insurance Model Act (PDF)

Comments on proposed updates to stop loss model provisions and their effect on self-insurance, particularly for small employers, in light of ACA requirements, submitted by AHIP; Blue Cross Blue Shield; Chambers of Commerce from Illinois, Pennsylvania, Texas and California; Cigna; Protect Health Care Choice Coalition; The Council of Insurance Agents & Brokers; HCC Life Insurance Company; Self-Insurance Institute of America, Inc.; American Insurance Association; and consumer representatives.

Comment Letter from Employers and TPAs to NAIC on Gudeline Amendments to the Stop Loss Insurance Model Act (PDF)

Comments submitted in advance of the ERISA Working Group meeting to be held on August 11, 2012, at which will be discussed proposals for the Stop Loss Insurance Model Act.

NAIC Delays Vote on Move to Hike Stop-Loss Attachment Points

"A proposal to raise specific attachment points in a stop-loss model act to a level that proponents of self-funding say would restrict smaller firms' ability to self-insure health benefits was delayed after an Aug. 11 debate hosted by the National Association of Insurance Commissioner's ERISA working group. The working group cited the need to study the proposal further. The Self-Insurance Institute of America believes the proposal -- which would triple specific stop-loss attachment points from $20,000 to $60,000 -- is designed to discourage self-funding, and create an environment that will funnel more workers working for small employers into the insurance exchanges created under the health reform law."