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ARA Backs Small Business AHP Proposal – and Offers Suggestions

The American Retirement Association (ARA) has lent its support to a Labor Department proposal on Association Health Plans – and offered a couple of recommendations as well.

Earlier this year, the U.S. Department of Labor announced a Notice of Proposed Rulemaking to expand the opportunity to offer employment-based health insurance to small businesses through Small Business Health Plans, also known as Association Health Plans. The announcement noted that up to 11 million Americans working for small businesses/sole proprietors and their families lack employer-sponsored insurance, and that those 11 million Americans could find coverage under this proposal, closing “the gap of uninsured without eliminating options available in the healthcare marketplace.”

In a comment letter in response, the ARA expressed its strong support for the proposal and its goal of expanding access to employer-sponsored health care coverage for American workers. “The firms that employ our members are typically small businesses,” the letter explained, going on to note that most of these small businesses have less than 50 employees each and, as such, must go through individual underwriting to provide health insurance coverage for their employees. The ARA strongly encouraged the Labor Department to “…finalize the Proposal as soon as possible.”

The ARA also provided some recommendations regarding the proposal, specifically that:

  • The final regulation be modified to permit the thousands of member-based associations that qualify for federal tax exemption under Internal Revenue Code Section 501(c)(6) the opportunity to sponsor an AHP. “Currently the proposal contemplates that the association sponsoring the AHP would do so for the benefit of its members who are employers,” the letter explained, depriving “thousands of associations whose membership is made up individual members the opportunity to sponsor an AHP.”

  • The Labor Department sponsor a forum for health insurers, service providers and associations interested in AHPs once the proposal is finalized. “There will be a need for dialogue among these parties to develop the right products that will fit the unique needs of AHPs, their association sponsors and the employers who will join them,” the letter says. “A DOL sponsored forum will accelerate the development process and the availability of AHPs in the marketplace.”

The comment letter is available online at