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District of Columbia Issues Guidance on Association Health Coverage

Bulletin 14-IB-01-10/23 issued on October 23, 2014 provides guidance regarding health insurance coverage sold to associations and small employers, including coverage sold to small employers located in the District by captive insurers domiciled outside of the District. The Bulletin addresses:

- Size of the individual employer and how the size determines whether the employer's coverage is subject to the small group market or the large group market rules.

- Mixed associations and how to treat members of the association.

- MEWAs and ERISA applicability and state insurance law applicability.

- Requirement for a captive insurer, association, or MEWA to obtain a certificate of authority and a person or entity that engages in the solicitation or sale of insurance to obtain a producer license. It reminds associations and MEWAs of form filing requirements.

Bulletin 14-IB-01-10/23 can be found by clicking here.

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