Update for Early Retiree Reinsurance Program Applicants

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The U.S. Department of Health and Human Services (“HHS”) has issued clarification of §149.40 of the Interim Final Rule, which has been interpreted to mean “first-come, first-served” processing of applications to the Program.

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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