Whittling away

THE NEW YORK ANTI-SABOTAGE ASSOCIATION HEALTH PLANS CASE

State of New York v. U.S. Dep’t of Labor No. 1:18-cv-1747 (D. D.C.)

Complaint, July 26, 2018

 

Summary judgment memo, August 23, 2018

Brown (Kentucky) declaration

Caride (New Jersey) declaration

Dutt (California) declaration

Gasteier (Massachusetts) declaration

Kofman (DC) declaration

Kreidler (Washington) declaration

MacEwan (Washington) declaration

Monahan (Pennsylvania) declaration

Navarro (Delaware) declaration

O’Connor (Maryland) declaration

Stolfi (Oregon) declaration

Taylor (DC) declaration

Vullo (New York) declaration

Whorley (Virginia) declaration

Lucia declaration

US motion for stay, September 4, 2018

Response to motion for stay, and cross-motion for schedule, September 7, 2018

Reply supporting stay, September 12, 2018

Order denying stay and setting schedule, September 14, 2018

Schedule: 1. Defendants shall file a certified list of the contents of the administrative record by not later than Tuesday, October 23, 2018.
2. Defendants shall file their combined motion to dismiss or, in the alternative, for summary judgment and opposition to plaintiffs’ motion for summary judgment by not later than Tuesday, October 30, 2018.
3. Plaintiffs shall file their combined opposition to defendants’ motion to dismiss or, in the alternative, for summary judgment by not later than Wednesday, November 28, 2018.
4. Defendants shall file their reply in support of their motion to dismiss or, in the alternative, for summary judgment by not later than Wednesday, December 19, 2018.

Index to administrative record, 10/23/2018

merged_86132_-1-1542045856

US motion to dismiss/opposition to summary judgment, 10/30/2018

5737310-0–20006

5737310-1–21503

merged_95655_-1-1541078670

US Chamber of Commerce amicus, 11/6/2018

merged_51389_-1-1541600020

Texas amicus, 11/7/2018

5748721-0–31066

New York reply/opposition, 11/28/2018

5772650-0–15099

As corrected via errata, 11/29 merged_77776_-1-1543719240

Clyburn amicus, 11/29/2018

5774174-0–17060

Restaurant Law Center motion for leave to file, 11/30/2018

merged_19502_-1-1543719510

AMA amicus, 12/5/2018

merged_15455_-1-1544192467

12/17/2018 MINUTE ORDER: Upon consideration of 31 plaintiffs’ motion for summary judgment; 47 government’s motion to dismiss for lack of jurisdiction or, in the alternative, cross-motion for summary judgment; and the entire record herein; a hearing on these motions is hereby set for January 24, 2019, at 9:30 a.m. in Courtroom 30 before Judge John D. Bates. Signed by Judge John D. Bates on 12/17/18. (lcjdb1) (Entered: 12/17/2018)

US motion to dismiss reply, 12/19/2018

5800889-0–2249

Coalition to Protect and Promote Association Health Plans amicus, 12/19/2018

5801802-0–25819

US motion to stay completion of joint appendix, 12/26/2018

5807067-0–24063

Plaintiffs’ opposition re stay, 12/27/2018

5807960-0–9489

California v. Ross motion and denial, 3:18-cv-1865 (N.D. Cal., 12/26/18), cited by plaintiffs

file0.12692275274652

12/27/2018 MINUTE ORDER: It is hereby ORDERED that any reply in support of 68 the government’s motion to stay shall be filed by not later than 6:00 p.m. today, December 27, 2018. Signed by Judge John D. Bates on 12/27/2018. (lcjdb2) (Entered: 12/27/2018)
12/27/2018 Set/Reset Deadlines: Any reply in support of 68 the government’s motion to stay shall be filed by not later than 6:00 PM on 12/27/18. (jth) (Entered: 12/27/2018)

US reply supporting stay, 12/27/2018

5809293-0–19772

Order denying stay and extending joint appendix deadline to January 9, 12/28/2018

5810765-0–2309

Filing about DC legislation, 1/4/2018

merged_54710_-1-1546652026

Notice of additional authority (California v. Trump), 1/4/2018

merged_29977_-1-1546652100

Joint appendix cover, 1/9/2019

5823504-0–1097

Notice of additional authority (census case), 1/23/2019

5840217-0–12203

state-of-new-york-et-al-v-united-states-department-of-commerce-et-al

Opinion, 3/28/2019

5940153-0–12659

Order, 3/28/2019

5940150-0–17368

Notice of appeal, 4/26/2019

5983378-0–13423

D.C. Circuit #: 19-5125

Unopposed motion to expedite

Document 35

Scheduling order, 5/10/2019

DCC scheduling order

US opening brief, 5/31/2019

DCC opening brief

Oklahoma Montana amicus, 6/4/or5/2019

DCC Oklahoma Montana amicus

Restaurant Law Center amicus, 6/7/2019

DCC Restaurant Law Center amicus

Texas and other states amicus, 6/7/2019

DCC Texas amicus

Chamber of Commerce of the US amicus, 6/7/2019

DCC Chamber of Commerce amicus

National Ass’n of Realtors amicus, 6/7/2019

DCC Realtors amicus

Coalition to Protect and Promote AHPs amicus, 6/7/2019

Coalition to Protect and Promote amicus

Corrected Chamber amicus brief, 6/18/2019

DCC Chamber of Commerce corrected amicus brief

Appellees’ brief, 7/15/2019

Document 63

Health Policy History Scholars amicus, 7/22/2019

DCC Health Policy History Scholars amicus

Members of Congress amicus, 7/22/2019

DCC Members of Congress amicus

Families USA amicus, 7/22/2019

DCC Families USA amicus

Small Business Majority amicus, 7/22/2019

DCC Small Business Majority amicus

Former State Insurance Commissioners amicus, 7/22/2019

DCC Former State Insurance Commissioners amicus

AMA amicus, 7/22/2019

DCC AMA amicus

Former Department of Labor Officials amicus, 7/22/2019

DCC Former USDOL Officials amicus

US reply brief, 7/25/2019

DCC USDOL reply brief

Order for 11/14 oral argument, 9/11/2019

DCC oral argument order

Transcript of D.C. Circuit oral argument, 11/14/2019

19-5125 11-14-19

Kentucky self-substitution motion, 12/16/2019

Kentucky substitution

US response to Kentucky motion, 12/18/2019

DCC US response to sub

D.C. Circuit Kentucky substitution order, 12/20/2019

DCC substitution order

 

Association health plans materials not (yet) filed in the case, 7/16/2019

Association health plans proposed regulations, 83 Fed. Reg. 614 (Jan. 5, 2018)

New York, etc., comments (March 6, 2018)

Association health plans, final rule, 83 Fed. Reg. 28912 (June 21, 2018)

Federal compliance assistance paper, August 2018

Secretary Azar’s speech, September 27, 2018
CBO study of association health plans and short term plans, January 2019
Department of Labor reaction questions and answers, March 28, 2019
S. 1170 (Sen. Enzi)
Floor statement, 165 Cong. Rec. S2438-39 (April 11, 2019)

CREC-2019-04-11-pt1-PgS2437

Letter from Republican AGs, February 21, 2019

JP9

Story re revival of Republican AGs’ proposal, July 2019

Safari – Jul 16, 2019 at 9:25 AM

 

THE DATA MARKETING PARTNERSHIP NORTHERN TEXAS CASE

Data Marketing Partnership, LP, v. U.S. Dep’t of Labor, No. 4:19-cv-800 (N.D. Tex.)

Complaint, with attachments, October 4, 2019

complaint

Exhibit A — request for advisory opinion

A — Request for Advisory Opinion

Exhibit B — Louisiana request

B — Louisiana request

Order for status report by 2/3, January 27, 2020

Order for status report by 2 3

Status report with advisory opinion, January 29, 2020

Joint status report with advisory opinion

Order re filing amended complaint, January 30, 2020

Order for filing amended complaint

Amended complaint, with exhibits, February 3, 2020

Amended complaint, with exhibits

Motion for preliminary injunction/TRO, February 3, 2020

motion for PI TRO

Memo in support, with exhibits, February 3, 2020

PI TRO memo with exhibits

Certificate of conference re TRO, February 3, 2020

certificate of conference re TRO

Order for scheduling meeting, February 6, 2020

Order for scheduling meeting

Joint scheduling statement, February 13, 2020

joint scheduling statement

Scheduling order, February 17, 2020

Scheduling order

Plaintiff’s motion for summary judgment/memo in support, February 19, 2020

Data Mark mo sj

Data Mark ms sj

DMP sj appendix index

DMP sj appendix 1

DMP sj appendix 2

Defendants’ cross-motion and supporting documents, March 9, 2020

US xmo

US tro pi op

US combined brief

Plaintiffs’ summary judgment reply, April 6, 2020

pltf sj reply

Additional exhibit, letter from Washington, filed April 7, 2020

exhibit

US cross-motion for summary judgment reply, April 24, 2020

US xms reply

Memorandum opinion, September 28, 2020

DMP opinion

Final judgment, September 28, 2020

DMP final judgment

Typo correction order, September 29, 2020

Typo correction order

US notice of appeal, November 27, 2020

Notice of Appeal 11 27 20

 

Not now filed in the case

Washington State Insurance Commissioner, Final Investigative Report, October 23, 2020

245511

 

THE COLUMBUS ANTI-SABOTAGE 2019 RULE TAKE CARE CASE

City of Columbus v. Trump, No. 1:18-cv-2364 (D. Md.)
Complaint, August 2, 2018

Columbus complaint

US motion to dismiss, with memorandum plus Wu declaration, December 24, 2018

Columbus US motion to dismiss

Columbus US memo supporting dism mo

Plaintiffs’ uncontested motion for extension to file amended complaint, December 31, 2018

Pltf uncontested motion for xt to file amended complaint

Order extending deadline, January 2, 2019

43 PAPERLESS ORDER GRANTING 42 consent motion for extension of time. Plaintiffs’ deadline to file an amended complaint is now extended to January 25, 2019. Signed by Judge Deborah K. Chasanow on 1/2/2019. (Chasanow, Deborah) (Entered: 01/02/2019)

Amended complaint, January 25, 2019

columbus amended complaint

Motion and memo to dismiss, with 2d Wu declaration, March 8, 2019

Columbus US mo dism

Columbus US ms dism

Columbus US Wu 2d dec

Unopposed motion for extension to respond, April 16, 2019

unopposed motion for xt

Opposition to motion to dismiss, with 2 exhibits, May 31, 2019

Opposition to motion to dismiss

Opposition exhibit A

Opposition exhibit B

Henry Aaron amicus, June 7, 2019

Aaron H amicus

California and other states amicus, June 7, 2019

California amicus

Families USA amicus, June 7, 2019

Families USA amicus

Joshua Peck amicus, June 7, 2019

Peck amicus

Thirteen counties and cities amicus, June 7, 2019

13 counties and cities amicus

US House amicus, June 7, 2019

US House amicus

US reply memo supporting motion to dismiss, August 21, 2019

US reply supporting motion to dismiss 2

Columbus additional authority (2 Baltimore cases), September 27, 2019

Columbus notice addl auth Balt 2 cases

Columbus Balt v. Trump

Columbus Balt standing

US response to Columbus additional authority, October 3, 2019

US response to Columbus addl auth

Memorandum opinion, with order, April 10, 2020

memorandum opinion

order

04/21/2020 105 PAPERLESS ORDER GRANTING 104 joint motion for the entry of an agreed-upon schedule and for an enlargement of page limitations. The administrative record pertaining to the 2019 Rule is due by June 17, Plaintiffs’ motion for summary judgment, limited to 60 pages, is due by August 13, Defendants’ consolidated opposition and cross-motion for summary judgment, limited to 60 pages, is due by September 17, Plaintiffs’ consolidated reply and opposition, limited to 40 pages, is due by October 15, and Defendants’ reply, limited to 40 pages, is due by November 12, 2020. Any prospective amici will file their motions to participate with accompanying brief by October 1, 2020. Signed by Judge Deborah K. Chasanow on 4/21/2020. (Chasanow, Deborah) (Entered: 04/21/2020)

Columbus motion for summary judgment, memo, request for judicial notice, [exhibits], August 13, 2020

Columbus mo sj

Columbus memo sj

Columbus rq jud n and x

Arwady dec

Dzirasa dec

Hinckley dec

Johnson dec

Matz dec

Muething dec

Vondra dec

Young dec

US summary judgment opposition/memo in support of cross-motion, September 28, 2020

US SJ op XSJ memo

Plaintiffs’ reply/opposition, October 26, 2020

pltf sj reply opposition

Shriver Center amicus, October 26, 2020

Shriver Center amicus 10 26 20

Young Invincibles amicus, October 26, 2020

Young Invincibles amicus 10 26 20

 

2019 Rule Materials not (yet) filed in the take care case, 9/27/18

“Minimizing the Economic Burden of the Patient Protection and Affordable Care Act Pending Repeal,” January 20, 2017

“Potential Administrative Marketplace Reforms,” discussed at a meeting, March 23, 2017

Democrats’ letter to Price and Verma, August 18, 2017

CMS, “Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2019,” 82 Fed. Reg. 51052 (Nov. 2, 2017)

Slavitt comments, Nov. 27, 2017

CMS, “Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2019,” 83 Fed. Reg. 16930 (April 17, 2018)

Correction, 83 Fed. Reg. 21925 (May 11, 2018)

CMS FACT SHEET, April 9, 2018
CMS Fact Sheet 4 9 18

2018 HARDSHIP EXEMPTION
CMS Guidance, April 9, 2018

2018-Hardship-Exemption-Guidance

CMS, “Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2020,” 84 Fed. Reg. 227 (Jan. 24, 2019), originally released Jan. 17, 2019
CMS, “Patient Protection and Affordable Care Act: HHS Notice of Benefit and Payment Parameters for 2020,” 84 Fed. Reg. 17454 (April 25, 2019)
CMS, “Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2021; Notice Requirement for Non-Federal
Governmental Plans,” 85 Fed. Reg. 7088 (Feb. 6, 2020)
CMS, “Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2021; Notice Requirement for Non-Federal
Governmental Plans,” 85 Fed. Reg. 25,164 (May 14, 2020)
Trump Administration proposed notice for 2022:
Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2022 and Pharmacy Benefit Manager Standards; Updates to State Innovation Waiver (Section 1332 Waiver) Implementing Regulations, November 25, 2020
HHS fact sheet, November 25, 2020

Decision in American Federation of Government Employees v. Trump, No. 1:18-cv-1261 (D. D.C., August 24/25, 2018)

 

THE ASSOCIATION FOR COMMUNITY HEALTH PLANS SHORT TERM LIMITED DURATION CASE

Association for Community Health Plans v. U.S. Dep’t of Treasury, No. 1:18-cv-2133 (D. D.C.)

Complaint, September 14, 2018

Consent motion for briefing schedule, September 24, 2018

10/02/2018 MINUTE ORDER. Upon consideration of the 4 Motion for Order Approving Proposed Agreed-Upon Briefing Schedule for Plaintiffs’ Motion for a Preliminary Injunction, it is hereby ORDERED that the motion is GRANTED. It is further ORDERED that defendants shall file their response to plaintiffs’ preliminary injunction motion no later than 10/15/18 and that plaintiffs shall file their reply no later than 10/22/18. It is further ORDERED that a preliminary injunction hearing shall be set for 10/26/18 at 3:00 PM in Courtroom 18 before Judge Richard J. Leon. SO ORDERED. Signed by Judge Richard J. Leon on 10/2/18. (lcrjl1) (Entered: 10/02/2018)

American Medical Association, etc., amicus paperwork, October 5, 2018

STLDI AMA amicus

American Cancer Society, etc., proposed amicus brief, October 8, 2018

5706537-1–2706

AARP amicus brief, October 8, 2018

5706571-1–26492

US response to PI motion, October 15, 2018

merged_81737_-1-1539696642

Errata version, October 22, 2018

5725123-2–23296-1

Plaintiffs’ preliminary injunction reply, October 22, 2018

5725754-0–17373

Transcript of the preliminary injunction hearing, October 26, 2018

Assoc for Comm Affil Plans et al v. U.S. Dept of Energy et al Oct 26 2018 PI Hrg Transcript

Withdrawal of PI motion/request for briefing schedule, November 7, 2018

merged_20234_-1-1541687545

Opposition to briefing schedule request, November 9, 2018

merged_61607_-1-1541791527

Reply supporting briefing schedule request, November 9, 2018

5751814-0–26292

Scheduling order, November 12, 2018

11/12/2018 MINUTE ORDER. Upon consideration of plaintiffs’ 28 Notice of Withdrawal of Motion for a Preliminary Injunction and Motion for Expedited Briefing Schedule, and defendants’ response thereto, it is hereby ORDERED that the following schedule shall govern the above-captioned case: (1) pursuant to Local Civil Rule 7(n)(1), defendants shall file a certified list of the contents of the administrative record with the Court and shall serve plaintiffs with a copy of the administrative record on or before December 19, 2018; (2) the parties shall file cross-motions for summary judgment, including references to the administrative record pursuant to Local Civil Rule 7(h)(2), on or before January 11, 2019; (3) the parties shall file any responses thereto on or before January 25, 2019; (4) the parties shall file any replies in support of their cross-motions for summary judgment on or before February 1, 2019; and (5) plaintiffs shall file the joint administrative records appendix as required by Local Civil Rule 7(n)(2) on or before February 8, 2019. It is further ORDERED that a motions hearing on the parties’ cross-motions for summary judgment shall be held on February 19, 2019 at 3:00 PM in Courtroom 18 before Judge Richard J. Leon. SO ORDERED. Signed by Judge Richard J. Leon on 11/12/18. (lcrjl1) (Entered: 11/12/2018)

Answer, November 19, 2018

5763046-0–32396

Motion for stay, December 31, 2018

merged_41436_-1-1546286139

Order for stay, December 31, 2018

12/31/2018 MINUTE ORDER. Upon consideration of 35 Defendants’ Motion to Stay Proceedings in Light of Lapse of Appropriations, it is hereby ORDERED that the Motion is GRANTED and the deadlines for the parties to file their summary judgment briefs in the above-captioned case are hereby STAYED until Congress has restored appropriations to the Department of Justice. It is further ORDERED that, within 14 days of the date of this Order, defendants shall file a status report with the Court addressing any developments bearing on the Department of Justice’s ability to litigate this action. SO ORDERED. Signed by Judge Richard J. Leon on 12/31/18. (lcrjl1) (Entered: 12/31/2018)

Status report and US motion for continued stay, January 14, 2019

merged_35658_-1-1547508360

Notice re appropriations, January 28, 2019

5847458-0–23305

Defendants’ proposed briefing schedule, February 1, 2019

merged_29998_-1-1549073047

02/05/2019 MINUTE ORDER. Upon consideration of defendants’ 38 Motion to Modify Briefing Schedule, it is hereby ORDERED that the Motion is GRANTED. It is further ORDERED that the following schedule shall govern the above-captioned case: (1) the parties shall file cross-motions for summary judgment on or before February 22, 2019; (2) the parties shall file any responses thereto on or before March 15, 2019; (3) the parties shall file any replies in support of their cross-motions for summary judgment on or before March 22, 2019; and (4) plaintiffs shall file the joint administrative records appendix as required by Local Civil Rule 7(n)(2) on or before March 29, 2019. SO ORDERED. Signed by Judge Richard J. Leon on 2/5/19. (lcrjl1) (Entered: 02/05/2019)

Plaintiffs’ motion for summary judgment, February 22, 2019

merged_26741_-1-1550947790

US cross-motion for summary judgment, including Wu declaration, February 22, 2019

merged_91327_-1-1550947836

American Cancer Society amicus, March 1, 2019

merged_61835_-1-1551468259

AARP amicus, March 1, 2019

merged_15245_-1-1551468322

AMA amicus, March 1, 2019

merged_99254_-1-1551468407

US summary judgment response brief, including proposed order, March 15, 2019

merged_23029_-1-1552695410

Plaintiffs’ summary judgment opposition, with Lyons-Berg declaration and proposed order, March 15, 2019

5921668-0–24214

5921668-1–22469-2

5921668-2–23289

US summary judgment reply, March 22, 2019

5931940-0–10459

Plaintiffs’ summary judgment reply, March 22, 2019

5932014-0–10923

Plaintiffs’ sealed motion re Foster declaration on standing, March 22, 2019

[sealed]

US opposition to plaintiffs’ motion re Foster declaration on standing, March 29, 2019

merged_24075_-1-1554058307

Plaintiffs’ opposition to US motion to strike Foster declaration on standing, April 5, 2019

merged_19504_-1-1554566459

05/02/2019 MINUTE ORDER. It is hereby ORDERED that a motions hearing on the parties’ cross-motions for summary judgment shall be held on May 21, 2019 at 03:00 PM in Courtroom 18 before Judge Richard J. Leon. Signed by Judge Richard J. Leon on 5/2/19. (lcrjl1) (Entered: 05/02/2019)

Memorandum opinion, order, July 19, 2019

stld memorandum opinion

stld order

Notice of appeal, July 29, 2019

6124695-0–18421

D.C. Circuit # 19-5212

Appellant statement of issues, August 30, 2019

DCC appellant statement of issues

Briefing schedule, September 23, 2019

DCC STLDI briefing schedule

Appellants’ brief, November 4, 2019

DCC appellant br

AMA amicus, November 7, 2019

DCC AMA amicus

Unopposed request for extension of time, November 8, 2019

DCC unopposed request for extension

House motion for leave and amicus, November 12, 2019

House notice of intent to participate amicus

House amicus

American Cancer Society amicus, November 12, 2019

American Cancer Society amicus

AARP amicus, November 12, 2019

AARP amicus

Order extending time for filing responsive brief, November 14, 2019

DCC xt order

Appellees’ brief, January 21, 2020

DCC appellees brief

Order for oral argument 3 20 20, January 24, 2020

DCC order for oral argument

Unopposed extension motion for reply brief 2 25 20, January 24, 2020

DCC unopposed mo xt reply

Buckeye Institute amicus, January 28, 2020

DCC Buckeye Inst amicus

Idaho notice re amicus, amicus, January 28, 2020

DCC Idaho notice re amicus

DCC Idaho amicus

Louisiana motion to participate as amicus, with amicus, February 17, 2020

DCC Louisiana motion for leave amicus

DCC Louisiana amicus

Corrected Louisiana amicus, February 18, 2020

DCC Louisiana amicus corrected 2 18

Order allowing Louisiana amicus, February 21, 2020

DCC order allowing LA amicus

Plaintiffs’ reply brief, February 25, 2020

DCC plaintiffs’ reply brief

D.C. Circuit oral argument order, March 17, 2020

DCC oral argument order

Opinion, July 17, 2020

D.C. Circuit opinion

Petition for rehearing en banc, August 31, 2020

DCC pet rheb

American Cancer Society motion to file amicus, and amicus, August 31, 2020

DCC ACA amicus mo

DCC ACA amicus rheb

Pennsylvania Wisconsin motion to file amicus, and amicus, September 8, 2020

PA WI motion for amicus

PA WI amicus

Families USA motion to file amicus and amicus, September 8, 2020

DCC Families mo and amicus

Order for response, October 9, 2020

DCC order for eb response

US unopposed motion to extend response date to November 10, October 9, 2020

DCC unop US mo xt rh resp

Order extending response time to 11 10, October 14, 2020

DCC xt rheb response order

US opposition to petition for rehearing en banc, November 10, 2020

DCC US rheb op

 

 

 

Short term limited duration materials not (yet) filed in the short term limited duration case, 9/28/18, updated with HIPAA materials 3/14/20

“Minimizing the Economic Burden of the Patient Protection and Affordable Care Act Pending Repeal,” January 20, 2017

Executive Order January 20 2017

Timothy Stoltzfus Jost, “LOOPHOLES IN THE AFFORDABLE CARE ACT: REGULATORY GAPS AND BORDER CROSSING TECHNIQUES AND HOW TO ADDRESS THEM,” 5 St. Louis U. Journal of Health Law & Policy 27 (2011).

JHLP5-1_Jost_Article

Text of HIPAA, Pub. L. No. 104-191
H.R. Rep. No. 104-496 (Ways and Means, March 25, 1996)
H. Conf. Rep. No. 104-793 (July 31, 1996)
Interim final regulations with comment period, 62 Fed.Reg. 16894 (April 8, 1997)
Final regulations, 69 Fed.Reg. 78720 (Dec. 30, 2004)

DOL/HHS, “Excepted Benefits; Lifetime and Annual Limits; and Short-Term, Limited-Duration Insurance,” 81 Fed. Reg. 75316 (October 31, 2016)

Republican letter to Secretary Price, 6/8/2017

[Executive order], 10/12/2017

Executive order [talking points], 10/12/2017

Executive order Q&A, 10/12/2017

Executive order graphic, 10/12/2017

Short term, limited-duration proposed regulations, 83 Fed. Reg. 7437 (Feb. 21, 2018)

Final rule, Federal Register version, 83 Fed. Reg. 38212 (Aug. 3, 2018)

Excerpts from President Trump’s New York Times interview, 12/28/2017

Senate Joint Resolution 63, introduced August 28, 2018
House Joint Resolution 140, introduced September 13, 2018
Secretary Azar’s speech, September 27, 2018

North Dakota bulletin, September 19, 2018

20180919Bulletin20182

Montana explanation

Short-term-limited-duration-health-insurance

US health policy paper, 12/18

Reforming-Americas-Healthcare-System-Through-Choice-and-Competition

Robert Wood Johnson/Urban study, 1/19

stldstudy119

CBO study of association health plans and short term plans, January 2019

 

CBO analysis of H.R. 1010, April 2019

hr1010

 

Chris Pope, Renewable Term Health Insurance: Better Coverage Than Obamacare (May 2019)

R-0519-CP

 

Author(s): Corlette S, Wengle E, Hill I, and Hoppe O,

Perspectives From Brokers: The Individual Market Stabilizes While Short-Term and Other Alternative Products Pose Risks

rwjf461012

 

Proposed regulations re grandfathered health plans, released July 10, 2020, to be published July 15, 2020

2020-14895