As I previously discussed, HHS has indicated a willingness to make an exception in the upcoming MLR regulations for mini-med plans. However, currently, it is unclear how and to what extent that exception will apply. Unfortunately, employers need to make decisions now for annual enrollment materials. Because no one knows what the MLR exception will look like, one solution to this issue is to simply self-insure your mini-med option. A self-insured mini-med option is not subject to the MLR regulations. However, remember, you still need to file for a waiver from the annual limits even if the option is self-insured.
While we are pleased to have you contact us by telephone, surface mail, electronic mail, or by facsimile transmission, contacting Kilpatrick Townsend & Stockton LLP or any of its attorneys does not create an attorney-client relationship. The formation of an attorney-client relationship requires consideration of multiple factors, including possible conflicts of interest. An attorney-client relationship is formed only when both you and the Firm have agreed to proceed with a defined engagement.
DO NOT CONVEY TO US ANY INFORMATION YOU REGARD AS CONFIDENTIAL UNTIL A FORMAL CLIENT-ATTORNEY RELATIONSHIP HAS BEEN ESTABLISHED.
If you do convey information, you recognize that we may review and disclose the information, and you agree that even if you regard the information as highly confidential and even if it is transmitted in a good faith effort to retain us, such a review does not preclude us from representing another client directly adverse to you, even in a matter where that information could be used against you.