Qs & As Part 2 on District Court ruling on Association Health Plan Regulations

Document Excerpt

On March 28, 2019, in State of New York v. United States Department of Labor, the United States District Court for the District of Columbia vacated portions of the Department of Labor’s
(Department’s) final rule on Association Health Plans (AHPs). The AHP rule, published on June 21, 2018, established a new test as an alternative to that described in prior Department subregulatory guidance for determining who can sponsor an ERISA-covered AHP as an “employer.” The AHP rule was intended to expand access to affordable, high-quality healthcare options,
particularly for employees of small employers. The Department disagrees with the district court’s ruling and filed a notice of appeal on April 26, 2019.


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