John S. Conniff is an attorney admitted to practice in Washington and Oregon. He attended Seattle University undergraduate and earned his law degree from Seattle University. He served as counsel to the Washington State Legislature, was Deputy Insurance Commissioner for Health care and now practices law in his own firm concentrating on health, insurance, and business matters.

The Health Care Reform Circus

In a loss deeply felt by grown-ups, the “Greatest Show on Earth” from Ringling Bros. and Barnum & Bailey will close forever in May. The Show featured a three-ring circus that overwhelmed and forced us to choose which of the simultaneous acts to watch. In choosing, we often missed something more exciting in another ring.…

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DOL Sues Spokane-Based Association Health Plan

On February 24th, the United States Department of Labor (DOL) sued Associated Industries of the Inland Northwest, Associated Employers Health and Welfare Trust, Associated Industries Management Service, Inc. (AIMS), and several individuals responsible for managing the Trust. DOL alleges “fiduciary breaches, prohibited transactions, and knowing participation in same.” The thirty-one page civil suit against the…

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Is free HR software an illegal inducement to buy insurance?

In December, the Washington State Insurance Commissioner ordered Zenefits to charge a market price for “use of its online, cloud-based, software platform that integrates the administration of human resources, payroll, and employee benefits.”  The Commissioner found that “free access to valuable software functions” constituted an illegal inducement to purchase insurance. Competing insurance brokers complained to the Commissioner that Zenefits’…

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ERISA Violations Get More Expensive

I’ve always admired the modesty of regulatory agencies and their polite expression of force. You might be pleased to learn that the Department of Labor (DOL) just issued interim final rules “to adjust the amounts of civil penalties assessed or enforced in its regulations.” Of course, if you understand official language, you know that the…

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