Articles, White Papers and Other Information

Trump Administration Argues Key Parts of ACA are Unconstitutional

In a filing before a district court, the DOL signals it will not defend key parts of the Affordable Care Act stating that once the Tax Cuts and Jobs Act zeros out the individual mandate penalty, the individual mandate, guaranteed issue and community ratings provisions become unconstitutional. Document Excerpt In sum, once the associated financial […]

House Subcommittee Seeks ERISA Changes

House Subcommittee seeks bipartisan proposals to update ERISA including encouraging defined contribution plans to provide annuities, eliminating the “common nexus” requirement for private multiple employer plans and other changes. Document Excerpt Subcommittee members and witnesses discussed four bipartisan proposals that would amend ERISA to better meet the retirement plan needs of employees and employers with […]

HHS Publication–Trump Proposal to Lower Drug Prices

HHS releases a publication discussing the Administration’s proposal to lower drug prices. Document Excerpt Link

White House Announces Intent to Nominate PBGC Director

The White House has announced its intent to nominate Gordon Hartogensis as director of the PBGC. Document Excerpt Link

HHS Blueprint for Lowering Drug Prices

HHS releases its blue-print for lowering drug prices and out-of-pocket cost and request for comments. Document Excerpt SUMMARY: Through this request for information, HHS seeks comment from interested parties to help shape future policy development and agency action. Link

SEC Fact Sheet on Proposed Best Interest Standard

In addition to its proposed regulation, the SEC also issued this Fact Sheet on its proposed best interest regulation. Document Excerpt Under proposed Regulation Best Interest, a broker-dealer would be required to act in the best interest of a retail customer when making a recommendation of any securities transaction or investment strategy involving securities to […]

SEC Proposed Interpretation of Best Interest Standard of Conduct

Along with the issuance of its proposed regulations, the SEC is also publishing a proposed interpretation of the standard of conduct and request for comments. Document Excerpt The Securities and Exchange Commission (the “SEC” or the “Commission”) is publishing for comment a proposed interpretation of the standard of conduct for investment advisers under the Investment […]

SEC Proposed Rule on Best Interest Standard

The SEC has issued a proposed regulation establishing a standard of conduct for broker-dealers and those associated with broker-dealers when making recommendations of securities transactions or investment strategies involving securities to retail customers. Document Excerpt This obligation shall be satisfied if: the broker-dealer or a natural person who is an associated person of a broker-dealer, […]

Guidance ending Special Enrollment Periods for 2017

CMS issues guidance ending special enrollment periods for coverage during calendar year 2017. Document Excerpt Consistent with our practice in prior years, as of April 1, 2018, CMS is no longer accepting new requests for a Special Enrollment Period (SEP) that would enable consumers to enroll in a Qualified Health Plan (QHP) with 2017 coverage […]

Q & A on Medical Loss Ratio Reporting and Rebate Requirements

CCIIO issues technical guidance in the form of Qs and As on the medical loss ratio reporting and rebate requirements. Document Excerpt The purpose of this bulletin is to supplement Q&A #18 in the July 18, 2011 CCIIO Technical Guidance1 and other prior guidance2 regarding the employee counting method for determining market size for purposes […]

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