ASAE is in the process of preparing comments on proposed rules released last week to expand association health plans (AHPs) as a means of providing access to affordable health coverage for small businesses and their employees.

Comments on the Department of Labor’s proposed rules are due March 6, 2018. ASAE will share its draft comments with the association community in the next few weeks to allow interested parties time to review and use as a model for their own comments if desired.

ASAE’s comments will focus on what types of organizations should qualify as an “employer” for the purposes of establishing an AHP (and who could participate in these AHPs), as well as the complexities associated with state regulation of AHPs. The proposed rule released last week would not preempt any current state regulations. Because the laws vary from state to state, AHP formation would be challenging without addressing state regulation.

Comments on the proposal can be submitted electronically at by referencing the Regulatory Identifier Number RIN 1210-AB85.