Regulatory Framework (B) Task Force
March 30, 2008

TheRegulatory Framework (B) Task Force met on Sunday, March 30, 2008.

At this meeting, the Task Force:

• Adopted its March 14, 2008 conference call minutes, which included adopting the Uniform Health Carrier External Review Model Act.

• Discussed HIPAA implementation issues with the Department of Labor representative. The Department of Labor discussed two recently issued Field Assistance Bulletins with these subjects: (1) Supplemental Health Insurance Coverage as Excepted Benefits under HIPAA and Related Legislation; and (2) Wellness Programs.

• Discussed developing a PEO informational paper.

• Received a report from the ERISA Subgroup. The Subgroup released for comment the Draft Regulator Alert -- Department of Labor Advisory Opinions 2007-06A When is a MEWA Fully Insured? and the Draft Regulator Alert – State Laws Giving Professional Employer Organizations (PEO’s) The Legal Status of Employer of Client Employers’ Workforce Can Open the Door to ERISA Preemption and State Law Challenges to State Restrictions on PEO’s Self Funding of Health Benefits. The Subgroup then met in Regulator-to-Regulator Session to discuss ongoing federal and state investigations into unauthorized MEWAs.

Action Items:

1. Adopted its March 24, 2008 conference call minutes.