Washington Revises Bona Fide Association Filing Standards

The Washington Insurance Commissioner (OIC) has proposed new rules to codify current procedures for filing large group health plans for bona fide associations. Under current requirements, the agency provides instructions for filing association health plans qualifying as a single large group plan under ERISA rather than rules governing these filings. The OIC requires that insurance…

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States sue DOL over new AHP rules

They said they would and they did. Twelve states filed a lawsuit against the Department of Labor (DOL) challenging DOL regulations liberalizing standards for creation and operation of Association Health Plans (AHPs). The complaint mirrors objections and comments submitted to DOL by a group of seventeen state attorneys general before the final rules were adopted.…

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DOL Final AHP Rules – Take a Breath

O.K., deep breath…slow down…no need to hyper-ventilate. Even if association health plans sold to small employers won’t include all of the “essential health benefits” mandated by the Affordable Care Act (ACA), that doesn’t mean the plans can be designed free from any regulatory constraints. Washington State association health plans will not suddenly appear on the…

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DOL Creates Two Kinds of AHPs – “Old School” and “New Age”

The U.S. Department of Labor (DOL) issued final regulations liberalizing standards for association health plans (AHPs) that DOL will recognize as single, large group health plans. The final regulations permit a more tenuous connection among participating employers and allow sole proprietors without employees to be considered employers. But the biggest change is the creation of…

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