Webinar: Association Health Plans – Is There a Pathway Forward?
When: Thursday May 30th
Time: 2 pm EDT
For supporters of “Association Health Plans (AHPs),” it has been a year-and-a-half roller coaster. It all started with excitement over President Trump’s Executive Order in October 2017, culminating in proposed Department of Labor (DOL) regulations issued in January 2018. Once the DOL regulations were finalized in June 2018, a good number of organizations immediately took steps to establish AHPs in accordance with the final rules (known as Pathway #2 AHPs), which kicked off coverage starting January 1, 2019. All was going well in the AHP-world!
Enter stage left…a DC District Court ruling invalidating the final AHP regulations on March 28. In the wake of the District Court ruling, the AHP-world has crumbled, aided by the Department of Justice’s (DOJ’s) decision not to request a “stay” of the ruling, which prompted the DOL to issue guidance informing existing Pathway #2 AHPs that they cannot expand their coverage to new participants, and existing participants may not re-enroll in their AHP plan for the 2020 coverage year. The DC Circuit Court of Appeals is not scheduled to uphold or overturn the district Court ruling in September or October of this year, with the Supreme Court’s consideration waiting in the wings. Meanwhile, AHPs that are formed under the DOL’s guidance issued prior to the release of the final AHP regulations (referred to as Pathway #1 AHPs) are unaffected by the District Court ruling, which means Pathway #1 AHPs can still be formed in most States with the State’s permission.
Join us for this complimentary, one-hour webinar as Christopher E. Condeluci, Principal and Sole Shareholder of CC Law & Policy, discusses in-depth about Pathway #1 and Pathway #2 AHPs, the DOL’s recent non-enforcement and Pathway #1 clarifying guidance, recent State activity, and the DC Circuit Court’s review of the District Court ruling.