The U.S. Department of Labor’s Employee Benefits Security Administration is proposing to rescind its regulation at 29 CFR 2510.3-5 that established alternative criteria for a group or association of employers to sponsor an association health plan (AHP) under the Employee Retirement Income Security Act (ERISA). The regulation’s alternative criteria were vacated in large part by a 2019 decision of the U.S. District Court for the District of Columbia in New York v. United States Department of Labor.
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- Paul J. Ray
December 22, 2023 - National Federation of Independent Business
David S. Addington
January 19, 2024 - Opportunity Solutions Project
Scott Centorino, Trevor Carlsen
February 2, 2024 - Members of U.S. Congress
Chuck Edwards, Kevin Hern, Dan Meuser, Claudia Tenney, Dan Crenshaw, Mark Amodei, David Rouzer, Carol Miller, Glenn "GT" Thompson, Ben Cline, William Timmons, Diana Harshbarger, Andy Ogles
February 6, 2024 - American Academy of Family Physicians
Tochi Iroku-Malize
February 8, 2024 - ICI Benefits Consortium (ICIBC)
Laura Bridges
February 14, 2024 - American Academy of Actuaries
Individual and Small Group Markets Committee and Active Benefits Committee
Jason Karcher, Benjamin Rayburn
February 14, 2024 - Medicare Rights Center
Fred Riccardi
February 14, 2024 - Asset Solutions Group
Jon M. Hager
February 15, 2024 - Elevance Health
Elizabeth P. Hall
February 15, 2024 - Timothy Stoltzfus Jost
February 15, 2024 - National Association of Insurance Commissioners
Andrew N. Mais, Jon Godfread, Scott White, Elizabeth Kelleher Dwyer
February 15, 2024 - Blue Cross Blue Sheild Association
Kris Haltmeyer
February 16, 2024 - Small Business Majority
John Arensmeyer
February 16, 2024 - Paragon Health Institute
February 17, 2024 - Medical Practice Consortium
W. James Hamilton, Curtis T. Jones
February 19, 2024 - United States of Care
Lisa Hunter
February 19, 2024 - The Association of Washington Business
Kristofer T. Johnson
February 19, 2024 - The Coalition to Protect and Promote Association Health Plans
Christopher E. Condeluci
February 19, 2024 - Credit Union Consortium, Inc.
Groom Law Group
Ryan C. Temme
February 20, 2024 - American Occupational Therapy Association
Laura Hooper, Emily Berlin
February 20, 2024 - American Cancer Society Cancer Action Network
Kirsten Sloan
February 20, 2024
- National Association of REALTORS
Kevin Sears
February 20, 2024 - Indiana Department of Insurance
Amy L. Beard
February 20, 2024 - Kaiser Permanente
Laird D. Burnett
February 20, 2024 - The Leukemia & Lymphoma Society
Bethany Lilly
February 20, 2024 - California Department of Insurance
Ricardo Lara
February 20, 2024 - Families USA
Yael Lehmann
February 20, 2024 - The Association for Community Affiliated Plans
Margaret A. Murray
February 20, 2024 - Point32Health
Christina Nyquist
February 20, 2024 - James Engstrand
Appendix 1 | Appendix 2 | Appendix 3
February 20, 2024 - Former Insurance Commissioners and NAIC Presidents, Former State Insurance Regulators, and Other Experts on AHP Fraud and Abuse
February 20, 2024 - District of Columbia Health Benefit Exchange Authority (HBX)
Mila Kofman3
February 20, 2024 - American Federation of State, County & Municipal Employees (AFSCME)
Dalia R. Thornton
February 20, 2024 - Center on Budget and Policy Priorities (CBPP)
Claire Heyison, Sarah Lueck
February 20, 2024 - United Hospital Fund
Peter Newell
February 20, 2024 - Council for Affordable Health Coverage (CAHC) and the Health Benefits Institute (HBI)
Joel White, J.P. Wieske
February 20, 2024 - Massachusetts Health Connector, the Massachusetts Division of Insurance, and the Massachusetts Office of the Attorney General
Audrey Morse Gasteier, Sandra Wolitzky, Gary Anderson
February 20, 2024 - National Health Law Program
Abbi Coursolle
February 20, 2024 - Indiana Bankers Association, Illinois Bankers Association, Nebraska Bankers Association, New Hampshire Bankers Association
Amber Van Til, Randy Hultgren, Katy Wolf Bode, Kristy Merrill
February 20, 2024 - Bernstein, Shur, Sawyer & Nelson, P.A.
Steven R. Gerlach
February 20, 2024 - Federation of American Hospitals (FAH)
Charles N. Kahn III
February 20, 2024 - AHIP
Adam Beck
February 20, 2024
- Partnership to Protect Coverage
American Cancer Society
Cancer Action Network
American Heart Association
American Kidney Fund
American Lung Association
Arthritis Foundation
Cancer Support Community
CancerCare
Crohn's & Colitis Foundation
Cystic Fibrosis Foundation
Epilepsy Foundation
Hemophilia Federation of America
Muscular Dystrophy Association
National Alliance on Mental Illness
National Bleeding Disorders Foundation
National Coalition for Cancer Survivorship
National Eczema Association
National Multiple Sclerosis Society
National Organization for Rare Disorders
National Patient Advocate Foundation
Pulmonary Hypertension Association
The Leukemia & Lymphoma Society
WomenHeart
February 20, 2024 - Pennsylvania Insurance Department
Michael Humphreys
February 20, 2024 - Washington State Health Benefit Exchange
February 20, 2024 - Members of U.S. Congress Committee of Education and the Workforce
Robert C. “Bobby” Scott, Mark DeSaulnier
February 20, 2024 - The Cigna Group
Kristin Julason Damato
February 20, 2024 - Iowa Bankers Plan
Chad Ellsworth
February 20, 2024 - U.S. Chamber of Commerce
Katie Mahoney
February 20, 2024 - American Bankers Association Office of the Insurance Advocacy
J. Kevin A. McKechnie
February 20, 2024 - Members of the State of Connecticut General Assembly
February 20, 2024 - Common Ground Healthcare Cooperative
Cathy Mahaffey
February 20, 2024 - Capital Benefits Group
M. Jonathan Hensley
February 20, 2024 - Building Industry Association of Washington
Gregory D. Lane
February 20, 2024 - National Association of Home Builders
Susan Asmus
February 20, 2024 - American Kidney Fund
Holly Bode
February 20, 2024 - UPMC Health Plan
Caleb B. Wallace
February 20, 2024