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"95% of HSA Are Still ERISA's"

 © 2004 - 2005  Jin Zhou,


HSA &/OR ERISA "95% of HSA Are Still ERISA's"

 © 2004 - 2005  Jin Zhou,

HSA Set Up ERISA??? if  with HSA Fund Distribution

If with HDHP of

QME,  Qualified Medical Expenses,    [IRC 213 (d)] CME, Covered Medical Expenses, [ERISA HDHP SPD]
If with HDHP of non- ERISA PLANS No No


In order to make HSA's (Health Savings Accounts) &/or ERISA understandable, as easy as 1-2-3, and a no-brainer for dummies, we present the official guide from the IRS, Treasury Department, DOL, Department Of Labor, Federal ERISA Enforcement Agency, with some experts views and industry news, to show the basic idea and a picture of the latest storm in healthcare market mixed with the most complicated ERISA law for 80% of US health care claims.




HSA &/OR ERISA, What's the Big Deal & Who Cares?


$5,000 to $10,000 deductibles for you and your family are and will be the way of your life this year and next year for the most and as popular insurance plans around the country.


If $10,000 or more is not a big deal to you, then HSA &/OR ERISA won't matter.

HSA Blue Eligible Plans (

  Plan 1 Plan 2 Plan 3 Plan 4
In-network Out-of-network In-network Out-of-network In-network Out-of-network In-network Out-of-network
Individual Deductible $2,500 $5,000 $2,500 $5,000 $2,500 $5,000 $2,500 $5,000
Family Deductible $5,000 $10,000 $5,000 $10,000 $5,000 $10,000 $5,000 $10,000
Maximum Annual HSA Contribution $2,500 ($5,000 for families)



Do you know 95% of HSA May Still Be ERISA's by HSA Set up and Fund Distribution (Fund Used for)?


HSA can be set up with or without ERISA exemption and HSA fund can be used with or without High Deductible Health Plan (HDHP) ERISA jurisdiction for employer-sponsored health plans in private sector.

Predicting the Future of Health Savings Accounts (PDF) (International Society of Certified Employee Benefit Specialists)

"The Department of Labor (DOL) has issued guidance as to the circumstances under which HSAs will or will not be subject to ERISA. In order to avoid ERISA, employer involvement with HSAs must be limited. While 58% of survey participants indicated that it would be somewhat or very likely that their organization would choose to avoid ERISA, a sizable minority (35%) said it was not very likely they would structure an HSA so as to avoid ERISA."

As HSA can only be set up on top of HDHP, and is mainly designed to offset and supplement high deductibles of ERISA plans, among other functions, the practical, legal and financial significance of ERISA compliance and risks of HSA have to be determined not only by HSA's design and set up but also more importantly by HSA's fund distribution, fund used to pay for ERISA health plan covered medical expenses in satisfying high deductibles and co-payments, for more than $2,500 to $10,000 deductibles, such as in HSA Blue Eligible Plans.

Blue Options - HSA Blue   With HSA Blue, you get... (

"Control of your health care budget

HSA Blue is an innovative, tax-free way for your employees to pay for current and future out-of-pocket health care expenses. HSA Blue pairs our most popular plan, the Blue Options PPO, with a health savings account (HSA). HSAs work like IRAs for qualified medical expenses. Funds can be used to pay for deductibles, over-the-counter medications, medical supplies and more. Get details about using HSA funds or review our list of FAQs."

Although HSA can be set up by anyone in addition to or other than employer, an individual covered under HSA must be covered by a HDHP and can not be covered by any other health plan that is not HDHP. Subject to certain requirements under ERISA regulation as explained in DOL Bulletin 2004-1, a HSA can be set up by design subject to ERISA regulation and jurisdiction.

Even if a HSA is set up with exemption of ERISA jurisdiction under HDHP of an ERISA plan, when such HSA fund distribution, money spent and used to pay for covered medical expenses in satisfying high deductibles and co-payments from ERISA HDHP, regardless who sponsored HSA or whether a HSA (account) itself constitutes an ERISA plan, such HSA fund distribution, by claiming and satisfying or applying to high deductibles in an ERISA HDHP,  has triggered ERISA jurisdiction and obligations of the plan administrator of the employer-sponsored, ERISA regulated, high deductible health plan. Therefore a non-ERISA HSA distribution can be an ERISA claim if HSA distribution is used to pay for covered medical expenses to satisfy and supplement deductibles and copayments of an ERISA plan, HDHP, which is the prerequisite for a HSA, as HSA was mainly designed to do by the President and Congress .

The Honorable John W. Snow Prepared Remarks: Health Savings Accounts Events (03/30/2004)

"Today we are issuing our next guidance in response to those comments that we received. Issues covered by the new guidance include a definition of “preventive care” and determining whether prescription drugs can be covered on a first-dollar basis or be subject to the high deductible under the high-deductible health plan that must accompany an HSA."

If a HSA is set up with exemption of ERISA jurisdiction, and HSA fund distribution is used to pay for qualified medical expenses under IRC 213 (d) without any interactions with an ERISA HDHP, such HSA will be completely exempted from ERISA jurisdiction.

If a HSA is set up without exception of ERISA jurisdiction, and HSA fund distribution can also be used for qualified medical expenses (QME), instead of cover medical expenses of an ERISA HDHP, such HSA design and set up will be subject to ERISA reporting and disclosure requirements, but irrelevant to ERISA HDHP claim adjudication, as HSA fund distribution adjudication is "Between the Taxpayer, God, and the IRS". However when such ERISA HSA fund distribution is used for covered medical expenses of an ERISA HDHP, such HSA set up and distribution are completely subject to ERISA regulation from beginning to the end.


HSA &/OR ERISA "95% of HSA Are Still ERISA's"

 © 2004 - 2005  Jin Zhou,

HSA Set Up

ERISA??? if  with HSA Fund Distribution

If with HDHP of

QME,  Qualified Medical Expenses,   

[IRC 213 (d)]

CME, Covered Medical Expenses, [ERISA HDHP SPD]
If with HDHP of non- ERISA PLANS No No





IRS Notice 2004-2: Q2 & A2 = HDHP & DOL Bulletin 2004-1: "The guidance makes clear that while private-sector employer-sponsored HDHPs are group health plans subject to ERISA’s reporting, disclosure, fiduciary responsibility and other requirements,...."

How many employers will offer HSA's without High Deductible Health Plans (HDHP) for health-care costs savings and control?

How many insurers will offer HSA products without health-insurance policies?

How many employees will set up their own HSA Accounts without their employers contributions and want $0.00 of medical expenses applied to their annual deductibles of their health insurance?

How many HSA trustees or custodians would risk ERISA fiduciary liabilities and the lawsuits by employers and employees if HSA claims are actually dual HSA and ERISA Claims?


Qualified Medical Expenses under HSA v. Cover Medical Expenses under ERISA Plans


Eligible medical expenses under HSA are governed under IRC §213 (d) as "qualified medical expenses" while covered medical expenses under ERISA health plans are determined by individual plans SPD (Summary Plan Description) under ERISA. A claim for incurred medical expenses could be qualified medical expenses under HSA but noncovered medical expenses under High Deductible Health Plan (HDHP) or both qualified medical expenses and covered medical expenses for each individual, and every individual is intended to be reimbursed from HSA and to apply that expenses to satisfy high deductibles under HDHP/ health-care plan under ERISA, regardless of future determination and outcomes.


A Claim of Incurred Medical Expenses in connection with HSA for benefits or satisfaction of deductibles under HDHP Triggers ERISA Jurisdiction


Although DOL has provided the following safe harbors for HSA claims to be exempted from ERISA regulations, practically speaking, every employee or eligible individual covered under high deductible health plans would have to satisfy such high deductible before benefits reimbursement can be made from the plan:

"Accordingly, we would not find that employer contributions to HSAs give rise to an ERISA-covered plan where the establishment of the HSAs is completely voluntary on the part of the employees and the employer does not: (i) limit the ability of eligible individuals to move their funds to another HSA beyond restrictions imposed by the Code; (ii) impose conditions on utilization of HSA funds beyond those permitted under the Code; (iii) make or influence the investment decisions with respect to funds contributed to an HSA; (iv) represent that the HSAs are an employee welfare benefit plan established or maintained by the employer; or (v) receive any payment or compensation in connection with an HSA. (Field Assistance Bulletin 2004-1)

Regardless whether a qualified medical expense under HSA will ultimately qualify for covered medical expenses in satisfying the plan's deductible in accordance with individual plan's SPD (Summary Plan Description) under ERISA, a claim submitted to and denied by an ERISA plan triggers ERISA jurisdiction under DOL FAQ C12:

"C-12: If a claimant submits medical bills to a plan for reimbursement or payment, and the plan, applying the plan’s limits on co-payment, deductibles, etc., pays less than 100% of the medical bills, must the plan treat its decision as an adverse benefit determination?


Under the regulation, an adverse benefit determination generally includes any denial, reduction, or termination of, or a failure to provide or make payment (in whole or in part) for, a benefit. In any instance where the plan pays less than the total amount of expenses submitted with regard to a claim, while the plan is paying out the benefits to which the claimant is entitled under its terms, the claimant is nonetheless receiving less than full reimbursement of the submitted expenses. Therefore, in order to permit the claimant to challenge the plan’s calculation of how much it is required to pay, the decision is treated as an adverse benefit determination under the regulation. Providing the claimant with the required notification of adverse benefit determination will give the claimant the information necessary to understand why the plan has not paid the unpaid portion of the expenses and to decide whether to challenge the denial, e.g., the failure to pay in full. This approach permits claimants to challenge whether, for example, the plan applied the wrong co-payment requirement or deductible amount. The fact that the plan believes that a claimant’s appeal will prove to be without merit does not mean that the claimant is not entitled to the procedural protections of the rule. This approach to informing claimants of their benefit entitlements with respect to specific claims, further, is consistent with current practice, in which Explanation of Benefits forms routinely describe both payable and non-payable portions of claim-related expenses. See § 2560.503-1(m)(4)."

In addition to plan SPD specific provisions in defining covered medical expenses, a claimant must also comply with plan provisions, as de facto control of HSA distribution by employer/the plan, in managed-care environment, such as pre-authorization, network provider limitations and utilization reviews, in order to be eligible for benefits, even for covered medical expenses.


In the course of such HSA ERISA exemption and ERISA claim practice to establish that an HSA claim may not be eligible for covered medical expenses in satisfying high deductibles under an ERISA plan, a plan fiduciary has to access, disclose and possibly provide for a copy of SPD, and to complete a full and fair review under ERISA for such "adverse benefits determination" of "an ineligible ERISA claim" of HSA expenses. In doing so, ERISA jurisdiction is inevitably triggered and ERISA compliance requirement is evidenced.


Contrary to mainstream assertion and predictions, this author believes that most HSA, up to 95%, will be ERISA claims regardless of their merits under current crisis-cost shifting managed-care environment. Failure in realizing this reality of ERISA compliance requirement will eventually increase health-care costs and managed-care litigations, and defeat entire purpose of timely medical care and health care quality in cultivating health-care disasters.

HSA & ERISA law affect patients, healthcare providers, insurance companies and TPA's  as well as employers.


We have received numerous comments and feedback on our comprehensive chapters and pages on this web site, requesting for a simplified "dummy version" of HSA's &/or ERISA page and a roadmap of the ERISA basics in health care claim appeals.


We would like to try this format to find out if we could accomplish this huge task. Please e-mail your questions and comments.





$$$$$$ ????? $$$$$$ ???????? $$$$$$ ?????????


BCBSA Approves Use Of Blue-Branded Debit Cards For Tax-Favored Health Savings Accounts (BCBSA Media Resources, February 1, 2005)


Blues Plans Join the Health Savings Account Train (Reuters, UK - Nov 17, 2004)


Blue Cross and Blue Shield Companies Offering HSA-Compatible Health Plans Across the Country, New Products Expand the Blues' Portfolio of Consumer-Directed Offerings (National Desk, Health Reporter U.S. Newswire (press release)


Most Blues Patients in Most States Will Have Access to Health Savings Accounts by the End of 2005 (American Medical News)


Kaiser's New High-Deductible Plan Signals Switch for Group-Model HMOs (MANAGED CARE WEEK via

Excerpt: "With Kaiser Permanente's decision this month to enter the consumer-directed market with a high-deductible HMO product, the managed care organization (MCO) becomes a highly visible sign of the continuing transformation of staff- and group-model HMOs toward fee-based products. HMO-focused plans are moving toward such products in greater numbers in an effort to remain competitive with employers seeking lower-cost plans."

Employees Do Not Think They Can Control Health Care Costs Survey Results Show (BenefitNews Connect via

Excerpt: "Employees are willing to take more control of their health care decisions, but are not quite sure how to do so, a Hewitt Associates poll of 39,000 employees shows. Among the consulting firm's findings: More than 80% of employees don't estimate their health care expenses each year. Nearly as many (79%) don't think they can do anything to control health care costs. More than half (57%) have never researched provider costs or quality."

Three Employers Compare Consumer-Directed Health Plan Design Notes During Audioconference (INSIDE CONSUMER-DIRECTED CARE via


Patients Cutting Health Care Usage: Higher Costs Force Workers to Make Difficult Decisions (The Mercury News; one-time registration required)

"• Nearly six out of 10 workers say they are avoiding their doctors until they experience serious symptoms -- a decision that could lead to costly bills that could have been avoided with preventive care."

Poor health, not lack of insurance, drives ED visits ... American Medical News

"The study published online Oct. 19 by the Annals of Emergency Medicine found that 85% of emergency patients had health insurance and 83% of ED visits were made by people who had a usual source of care such as a primary care physician. People without insurance were no more likely to visit the emergency department than people with insurance."

Does lack of a usual source of care or health insurance increase the likelihood of an emergency department visit? Results of a national population-based study," Annals of Emergency Medicine


Comments on and Excepts from Recent Articles on the Implementation of Health Savings Accounts (Attorney B. Janell Grenier via

Excerpt: "Generally, payment with HSAs should work the same way payments generally work for patients with insurance. The doctor informs the insurer of the charges, the insurer sends the patient a statement explaining how much the patient owes, and the patient then has to pay the doctor that amount. Patients using HSAs should wait to pay until the doctor submits the information to their insurer, says Mr. Engel of Mellon Financial. . ... Some insurers, like UnitedHealthcare, are already working to minimize this hassle, for example, by allowing consumers to authorize the insurer to deduct directly from their HSAs to pay medical bills."

Wall Street Journal Looks at Use of and Confusion with Health Savings Accounts (Kaiser Family Foundation)

Excerpt: "The Wall Street Journal on [November 30] examined some of the challenges facing consumers, insurers and banks as the health care industry works out the details of health savings accounts. One 'potential are[a] of confusion' is 'when and how much' patients with HSAs should pay providers, the Journal reports. According to the Journal, some providers and consumers 'are confusing HSAs with direct, full-price payments' made by the uninsured. In fact, consumers with HSAs are expected ...."

HSA Adjudication Is "Between the Taxpayer, God, and the IRS" (Spencer Benefits Reports)

"Health savings account owners may use HSA funds to pay for their spouse's and/or dependents' medical expenses, even if the spouse or dependents are not enrolled in the employee's high-deductible plan or have coverage under another employer's plan, said Kevin Knopf, attorney adviser in the Treasury Department's Office of Benefits Tax Counsel. Mr. Knopf spoke and answered questions at a January 13 teleconference sponsored by the American Bar Association's joint committee on employee benefits."

Predicting the Future of Health Savings Accounts (PDF) (International Society of Certified Employee Benefit Specialists)

"The Department of Labor (DOL) has issued guidance as to the circumstances under which HSAs will or will not be subject to ERISA. In order to avoid ERISA, employer involvement with HSAs must be limited. While 58% of survey participants indicated that it would be somewhat or very likely that their organization would choose to avoid ERISA, a sizable minority (35%) said it was not very likely they would structure an HSA so as to avoid ERISA."

Half of Insured Adults with High-Deductible Health Plans Experience Medical Bill or Debt Problems (The Commonwealth Fund)

Press Release Press Release (102K) [download]

Davis Presentation (PDF B&W) Davis Presentation (PDF B&W) (59K) [download]

Davis Presentation (PPT) Davis Presentation (PPT) (219K) [download]

Davis Presentation (PDF, color) Davis Presentation (PDF, color) (62K) [download]

Excerpt: "About half of insured adults with a high-deductible health plan have medical bill problems or debts, compared with less than one-third (31%) of those with lower-deductible plans, according to new research from The Commonwealth Fund. Individuals with high-deductible plans are also more likely than those with lower-deductible plans to experience access problems such as not filling a prescription, or skipping a medical test, treatment, or follow-up when needed, due to cost."

Half of bankruptcy due to medical bills-US study (Reuters AlertNet)


"WASHINGTON, Feb 2 (Reuters) - Half of all U.S. bankruptcies are caused by soaring medical bills and most people sent into debt by illness are middle-class workers with health insurance, researchers said on Wednesday."

Wall Street Journal Examines Concerns about Medical Evidence Used for Best-Practice Guidelines (The National Journal Group, Limited via The BlueCross BlueShield Association)


Opinion: Risks and Benefits: Health Savings Accounts and Employee Ability to Handle Risk and Costs (


Bush Promotes Health Savings Accounts: Plan Would Cut Costs and Increase Patient Responsibility (The Washington Post; one-time registration required)


Early Response Suggests Health Savings Accounts Products Are Popular in the Individual Market (American Medical News)


Employee Benefits Security Administration Issues Field Assistance Bulletin on Health Savings

"The guidance makes clear that while private-sector employer-sponsored HDHPs are group health plans subject to ERISA’s reporting, disclosure, fiduciary responsibility and other requirements, HSAs generally will not constitute ERISA-covered employee benefit plans. The guidance also clarifies that an employer can make contributions to the HSA of an eligible individual without being considered to have established or maintained the HSA as an ERISA-covered plan, provided that the employer’s involvement with the HSA is limited."


Field Assistance Bulletin 2004-1

"Whether Health Savings Accounts established in connection with employment-based group health plans constitute "employee welfare benefit plans" for purposes of Title I of ERISA?"



HSAs generally will not constitute "employee welfare benefit plans" for purposes of the provisions of Title I of ERISA. Employer contributions to the HSA of an eligible individual will not result in Title I coverage where, as discussed above, employer involvement with the HSA is limited. Finding that an HSA established by an employee is not covered by ERISA does not, however, affect whether an HDHP sponsored by the employer is itself a group health plan subject to Title I. In fact, unless otherwise exempt from Title I (e.g., governmental plans, church plans) employer-sponsored HDHPs will be employee welfare benefit plans within the meaning of ERISA section 3(1) subject to Title I."

Text of IRS Notice 2004-2: Guidance on Health Savings Accounts (PDF) (Internal Revenue Service) (Selected)


Q-1. What is an HSA?


A-1. An HSA is a tax-exempt trust or custodial account established exclusively for the purpose of paying qualified medical expenses of the account beneficiary who, for the months for which contributions are made to an HSA, is covered under a high-deductible health plan.


Q-26. What are the “qualified medical expenses” that are eligible for tax-free distributions?


A-26. The term “qualified medical expenses” are expenses paid by the account beneficiary, his or her spouse or dependents for medical care as defined in section 213(d) (including nonprescription drugs as described in Rev. Rul. 2003-102, 2003-38 I.R.B. 559), but only to the extent the expenses are not covered by insurance or otherwise. The qualified medical expenses must be incurred only after the HSA has been established. For purposes of determining the itemized deduction for medical expenses, medical expenses paid or reimbursed by distributions from an HSA are not treated as expenses paid for medical care under section 213.


Q-29. Must HSA trustees or custodians determine whether HSA distributions are used exclusively for qualified medical expenses?


A-29. No. HSA trustees or custodians are not required to determine whether HSA distributions are used for qualified medical expenses. Individuals who establish HSAs make that determination and should maintain records of their medical expenses sufficient to show that the distributions have been made exclusively for qualified medical expenses and are therefore excludable from gross income."


JS-2112: Treasury and IRS Issue Indexed Amounts for Health Savings Accounts




November 19, 2004


Treasury and IRS Issue Indexed Amounts for Health Savings Accounts


The Treasury Department and IRS today issued new guidance on the maximum contribution levels for Health Savings Accounts (HSAs) and out-of-pocket spending limits for High Deductible Health Plans (HDHPs) that must be used in conjunction with HSAs. These amounts have been indexed for cost-of-living adjustments for 2005 and are included in Revenue Procedure 2004-71, which announces changes in several indexed amounts for purposes of the federal income tax. The minimum deductible required for HDHPs did not change.


"Today's guidance will help consumers and employers who wish to participate in HSAs in 2005 to plan accordingly," said Treasury's Acting Assistant Secretary for Tax Policy Greg Jenner. "Knowing the dollar limits for these accounts, and for the high deductible insurance that goes with them, is critical for those who want to get the maximum benefit out of this revolutionary health care coverage option – one that puts health care spending decisions back in the hands of individuals."


The new levels are as follows:


New Annual Contribution Levels for HSAs:

  • For 2005, the maximum annual HSA contribution for an eligible individual with self-only coverage is $2650. (Note: for any individual, the maximum contribution is the lesser of the indexed amount or the deductible of the HDHP.)
  • For family coverage the maximum annual HSA contribution is $5250.
  •  Catch up contributions for individuals who are 55 or older is increased by statute from $500 to $600 for 2005.
  •  Both the HSA contribution and catch up contribution apply pro rata based on the number of the months of the year a taxpayer is an eligible individual, and, with respect to the catch up contribution, the number of months of the year that the taxpayer is age 55 and over.


New Amounts for Out-of-Pocket Spending on HSA-Compatible HDHPs:

  •  The maximum annual out-of-pocket amount for HDHP self-coverage increases to $5,100 and the maximum annual out-of-pocket amount for HDHP family coverage is twice that, $10,200.

Minimum Deductible Amounts for HSA-Compatible HDHPs:

  • For 2005, the minimum deductible for HDHP is unchanged, remaining at $1,000 for self-only coverage and $2,000 for family coverage.





‘‘Medicare Prescription Drug, Improvement, and Modernization Act of 2003’’ (pdf) (415) (A full text of the H.R. 1)


The corrected 2005 Publication 15-B, Employers Tax Guide to Fringe Benefits (PDF) (or HTML version), is now available for download. --04-FEB-2005

If you downloaded the 2005 version of Publication 15-B before February 3, 2005, please make a note of the following correction.

The discussion of cafeteria plans on pages 2 and 3 of the publication incorrectly indicated that health savings accounts could not be included in cafeteria plans. Previous references to health savings accounts have been deleted from the text under "Qualified benefits" and "Benefits not allowed" in that discussion.


Health Savings Accounts (HSAs) were created by the Medicare bill signed by President Bush on December 8, 2003 and are designed to help individuals save for future qualified medical and retiree health expenses on a tax-free basis."


Frequently Asked Questions

Technical Guidance

All About HSAs Icon: PDF Document

Tax Savings from HSA Contributions Made in 2005 Icon: PDF Document

IRS Forms and Publications

HSA Statute Icon: PDF Document


Press Releases

JS-1061: Treasury Issues Guidance To Encourage Use Of New Innovative Health Savings Accounts ("HSAs")

Text of IRS Notice 2004-2: Guidance on Health Savings Accounts (PDF) (Internal Revenue Service)

13 pages. Excerpt: "This notice provides certain basic information about HSAs in question and answer format, without attempting to enumerate all of the specific rules that apply under section 223. The notice is divided into five parts. Part I of the notice explains what HSAs are and who can have them. Part II describes how HSAs can be established. Parts III and IV cover contributions to HSAs and distributions from HSAs. Part V discusses other matters relating to HSAs."

IRS Modifies HSA Eligibility Rule for 2004, 2005 for Individuals Covered by Prescription Drug Plan (PDF) (Internal Revenue Service)


Rev. Rul. 2004-38 Clarifies HSA Eligibility Rule for Individuals Covered by Prescription Drug Plans (PDF) (Internal Revenue Service)


IRS Provides Safe Harbor for Preventive Care Benefits Under High-Deductible Health Plan (PDF) (Internal Revenue Service)


HSAs Established Before April 15, 2005 Can Cover Expenses Incurred On or After January 1, 2004 (PDF) (Internal Revenue Service)


Frequently Asked Questions About Health Savings Accounts (HSAs) (U.S. Treasury Department)


Text of Rev. Rul. 2004-45 on Interaction of Health Savings Accounts with Other Health Arrangements (PDF) (Internal Revenue Service)


JS-1535: Treasury Clarifies Interaction Of Health Savings Accounts With Other Employer-Provided Health Reimbursement Plans


Draft Form Issued by IRS: Model Health Savings Account for Use by Trustees (PDF) (Internal Revenue Service)


Draft Form Issued by IRS: Model Health Savings Account for Use by Custodians (PDF) (Internal Revenue Service)


Text of Notice 2004-50 Providing 88 Q&As on Health Savings Accounts (PDF) (Internal Revenue Service)

30 pages. Excerpt: "This notice provides guidance on Health Savings Accounts.... Notice 2004-2, 2004-2 I.R.B. 269, provides certain basic information on HSAs in question and answer format. This notice addresses additional questions relating to HSAs."

Text of Notice 2004-50 Providing 88 Q&As on Health Savings Accounts (PDF) (Internal Revenue Service) (Revised and corrected--Aug. 9, 2004)  32 pages


IRS Announcement 2004-67 (Sept. 7, 2004) (page 54 of 57)

"The last sentence in A–14 of Notice 2004–2 which currently reads, “After an individual has attained age 65 (the Medicare eligibility age), contributions, including catch-up contributions, cannot be made to an individual’s HSA”, is corrected to read as follows: “After an individual has attained age 65 and becomes enrolled in Medicare benefits, contributions, including catch-up contributions, cannot be made to an individual’s HSA.” Additionally, the terms “becomes eligible for” in the first sentence of the Example in A–14 of Notice 2004–2 are replaced by “becomes enrolled in”.

Final Versions of Combined HSA/Archer MSA Reporting Forms and Instructions for Trustees and Custodians: Form 1099-SA and Instructions  Form 5498-SA


Text of Proposed Regs for Medicare Prescription Drug Benefit (PDF)
233 pages. (Centers for Medicare & Medicaid Services, Department of Health and Human Services)


Overview of Health Savings Accounts With Chart Comparison to Archer MSAs, HRAs and FSAs (PDF) (Miller & Chevalier Chartered)


How Health Savings Accounts Compare To FSAs and HRAs (Groom Law Group)


Overview: Health Savings Accounts-- Favorable IRS and DOL Guidance (Groom Law Group)


Analysis: Comprehensive HSA Guidance Clarifies Many Issues, Sets Forth Several New Rules (Groom Law Group)


ERIC Summary Outline for Employer Sections (Title 1; J & R) of the Medicare Regulations (ERISA Industry Committee)


ABA Joint Committee on Employee Benefits Agency Q-As


ABA Reports Various Employee Benefit Regulators' Views on Health Issues (Deloitte's Washington Bulletin)


Overview: 2005 Medicare Premiums, Deductibles and Coinsurance (The Segal Company)


HSA Adjudication Is "Between the Taxpayer, God, and the IRS" (Spencer Benefits Reports)


Overview: Irs, Treasury Resolve Key HSA Issues (Business Insurance)


American Benefits Council Comments on IRS HSA Guidance (PDF) (American Benefits Council)


Not Everyone Sees Health Savings Accounts as a Panacea -- Wait and See Attitude Reported (Workforce Management)


AMA's 'Health Savings Accounts at a Glance' Brochure Explains How Health Savings Accounts Work (PDF) (American Medical Association)


Chart: 2005 Minimums and Maximums for High-Deductible Health Plans, HSAs and MSAs (The Segal Company)

Excerpt: "The Internal Revenue Service (IRS) recently released Revenue Procedure 2004-71, which announced various inflation-adjusted amounts for 2005.1 The new numbers for high-deductible health plans (HDHPs), Health Savings Accounts (HSAs) and Archer medical savings accounts (MSAs) are shown in the first of the two charts below. The second chart notes the maximum annual HSA contributions for 2005."

Three Employers Compare Consumer-Directed Health Plan Design Notes During Audioconference (INSIDE CONSUMER-DIRECTED CARE via

Excerpt: "Although their plan designs are different, three benefits leaders who helped launch consumer-directed health (CDH) plans for their employers agree that their core reasons for implementing a CDH plan are the same: provide an incentive for employees to be better consumers of health care. Employee benefits leaders representing three CDH strategies -- from three different administrators -- discussed the design elements of their plans during a Nov. 10 audioconference sponsored by AIS."

HSA Road Rules for Consumers, Employers, Insurers, Banks, Credit Unions and Administrators (PDF) (HSA Coalition)



ERISA Failure Syndrome

U.S. Healthcare Crisis Trilogy

(Copyright © 2004 by Jin Zhou,


Medical Killing
Medical Inflation
Insurance Robbery
"Health Insurance Challenges: Buyer Beware" 3-3-04
Hearing, Senate Committee on Finance

Read Making a Killing




Bar graph showing trends in hospital charges and revenues in California from 1995-2002






American Job ExportING!

Mass layoffs up in January 2004

Weirton Steel cancels 10,000

GM: $67.5 billion in 2003

One Nation under Debt: U..S. economy threatened by aging of America


Healthcare Disaster at Fault Verdict Index:

U.S. Government 30%

U.S. Employers & Insurers 30%

Healthcare Providers 30%

Consumers 10%

(ERISA Failure + Managed-Care) Destroyed US Healthcare
(ERISA Failure + Managed-Care + HSA) Invite US Federal Budget Deficit & Social Security Disasters = 100X 9/11 Attacks


GAO: Current and Emerging Fiscal and Retirement Security Challenges, American Benefits Council/MetLife Conference, Washington, DC, on January 14, 2005

  1. Rising Health care Costs Have Many Implications (Direct)

  2. Rising Healthcare Costs Have Many Implications (Indirect)


Rx-1  $$$$$$$$$ERISA"Health Insurance Challenges: Buyer Beware" 3-3-04
Hearing, Senate Committee on Finance
$$$$$$$$$$  Rx-2




U.S. Health-care Crisis & ERISA Criminal Enforcement


950,000 MD's Settled With Aetna & Cigna on ERISA


Aetna + CIGNA Settlement

 © 2004  Jin Zhou,


Settlements = ERISA + 3 E. B.

(Click on each hyperlinks for details)


"Aetna and CIGNA Settlement Secrets"

"Talking Points"


  1. ERISA stands for Employee Retirement Income Security Act

  2. E. B. = External Boards (of Reviews) (§7.10-7.11): 1) Medical Necessity, 2) Billing & Coding and 3) Policy Coverage

  3. Settlements Only for MCO/Provider Contract Disputes

  4. Settlements Not for Patient Coverage/ERISA Disputes, (§7.10-7.11)

  5. Patient Disputes = ERISA/Coverage/Medical Necessity/Bundling & Down Coding

  6. Provider Disputes = PPO Discount/HMO Capitation/Provider Relationship (DOL FAQ A8)

  7. Patient Disputes Provider Disputes, (DOL FAQ A8); Provider/MCO Contract (PPO/HMO) Disputes are not Triggered until Patient ERISA Disputes With the ERISA Plan Are 100% Resolved or Moot (DOL FAQ C12) (PASCACK VALLEY HOSPITAL, INC. v  LOCAL 464A UFCW WELFARE REIMBURSEMENT PLAN (3rd Cir. 11/01/2004)

  8. External Reviews (3 E. B.) Are Not Available until Internal Reviews (ERISA) Completed, (GAO)

  9. ERISA = Federal Law Mandate; External  Reviews = State Law Mandate, (GAO)

  10. No ERISA Compliance = No Rights for Any One

Birthday Sept. 2,


Happy or Sad 30th Birthday To ERISA?

(Copyright © 2004 by Jin Zhou,

Sept. 2, 2004

On Sept. 2, 1974, exactly 30 years ago today, ERISA, The Employee Retirement Income Security Act, was signed into law by President Gerald R. Ford. The congressional intent in enacting ERISA was to protect employees in pension and welfare plans, to provide uniform federal protections in response to the failure of the Studebaker Co. in December 1963, with thousands of long-service employees cheated out off their promised pensions, and to preempt any state laws when the employees pension and welfare benefits were threatened. 30 years later, ERISA Failure in its compliance and enforcement left thousands of retirees without medical benefits, and resulted in a skyrocketing national healthcare expenditure explosion with 45 million uninsured and a possible national pension bailout.

ERISA Failure Syndrome

U.S. Healthcare Crisis Trilogy


Jin Zhou Identifies "ERISA Failure" That Killed U.S. Healthcare

"Failure of Imagination" Again?




ERISA Celebrates 30th Anniversary As Trouble Brews For the Pension Insurance Program (Spencer Benefits Reports)

Excerpt: "The seed for ERISA was planted with the failure of the Studebaker Company in December 1963, leaving thousands of long-service employees without their promised pensions."

A Hard-to-Swallow Lesson on Pensions and Promises and ERISA (The New York Times; one-time registration required)

Excerpt: "Hundreds of people here in western New York, all closing in on retirement, have learned a bitter lesson about pensions and the law that guarantees them. Two years ago, their employer, ... unexpectedly started urging them to take their pensions early, warning that they would otherwise lose their right to take their benefits in a single check. The workers signed up to receive their money right away, but the money was much less than they had earlier been told they had coming."

The Economic Downturn and Changes in Health Insurance Coverage, 2000-2003, (Kaiser Commission on Medicaid and the Uninsured)

 Other Resources Icon Executive Summary (.pdf)    Reports and Studies Icon Report (.pdf)


The number of uninsured Americans under age 65 increased by 5.1million between 2000-2003 largely driven by continuing declines in employer sponsored insurance. ....."

The Supreme Court and Employee Health Insurance (FindLaw's Writ - Sebok)

"What Americans generally don't know, however, is that this issue isn't restricted to the Congress or the Executive. To the contrary, the U.S. Supreme Court has been nationalizing one important aspect of health care in this country: the administration of medical health insurance offered by employers to their employees.


This creeping nationalization has been achieved slowly and surely by the expansion of the court's interpretation of an important federal law: the Employee Retirement Income Security Act (ERISA)."

Inquiry on Medicare Finds Improper Limits on Choices of Health Care Providers (The New York Times; one-time registration required)

Excerpt: "Federal investigators said Monday that the Bush administration had improperly allowed some private health plans to limit Medicare patients' choice of health care providers, including doctors, nursing homes and home care agencies."

Medicare Demonstration PPOs: Financial and Other Advantages for Plans, Few Advantages for Beneficiaries GAO-04-960, September 27, 2004

Abstract    Highlights-PDF    PDF 



Brief Summary Of the New Regulation

for Physicians and ERISA Plans/TPAs

Effective Date: January 01, 2003


For Physicians and Health-care Providers

For Insurance Companies

ERISA's Prompt Pay Law, better than State Prompt Pay Laws  [29 CFR § 2560.503-1 (f)(i), Page 70267-9] ERISA's Prompt Pay Law, better than State Prompt Pay Laws [29 CFR § 2560.503-1 (f)(i), Page 70267-9]
New Assignment of Benefit Form Required for Appeals and Claim Dispute (DOL FAQ, B2-B3) No New Legal Assignment of Benefit Form, No Obligations to Physicians and Health-care Service Providers (DOL FAQ B2), otherwise Obligations to Disclose to Both Patients and Providers (DOL FAQ B-3)
No written appeal, no rights, except for claims involved with urgent care. [Page 70255 & 70271] In claims involved with urgent care, physicians/health-care providers are to be considered by default as authorized representatives. [Page 70255 & 70271]
The regulation clarifies for the first time since 1977 and prohibits anti-assignment provisions in ERISA plans & (footnote 36). [page 70255 ] [29 CFR § 2560.503-1 (b) (4) Page 70266] Assignments by patients must be absolutely clear as to what extent and capacity, verifications are permitted & (footnote 36). (DOL FAQ B-3) [page 70255 & 70266] [29 CFR § 2560.503-1 (b) (4), Page 70266]
Must complete required two levels of appeals, with legal assignment of benefits and specific written request for disclosure of specific plan documents. [Page 70253] No legal assignment of benefits, no response required; no specific written request, no disclosure obligated, however failure to establish and comply with claim procedures, administrative remedies are considered to be exhausted. Lawsuit may follow. [Page 70271]
New protections for pre-service claims and urgent care claims against improper pre-authorization, pre-certification and utilization review as well as urgent cares. [Page 70248 & 70271] Understanding of differences in pre-service, urgent care and post-service claims will save big money in fiduciary breach liability claims and POSSIBLE medical malpractice claims[Page 70248 & 70271]
New definitions of relevant documents and disclosure obligations, no more medical necessity secrets, UCR fee schedule confidential [Page 70252]  [29 CFR § 2560.503-1 (h)(2)(iii) (m) (4), Page 70268, 70271] [DOL FAQ B-5] No legal assignment of benefits, no obligation to disclose to an assignee, assignment verification by the plan is allowed and protected. Update SPD and any guidelines, only use disclosable and qualified medical claim reviewers. [Page 70252]  [29 CFR § 2560.503-1 (h)(2)(iii) (m) (4), Page 70268, 70271] [DOL FAQ B-5]
A Full and Fair Review with new definitions and protection requires de novo reviews on two appeals by at least four different people, two different fiduciaries with ERISA plan, and two different Health-care professionals independent to the ERISA plan. [29 CFR § 2560.503-1 (h) (3)(ii)(iii)(iv)(v), Page 70268-9, (m) (8), Page 70271] [Page 70252-70253] Update SPDs with New Standards and compliance, specify and designate only qualified fiduciaries for appeals, establish new complaint appeal procedures, use only disclosable and licensed as well as certified health-care professionals for medical reviews, pre-certification and prior authorizations in every case. [29 CFR § 2560.503-1 (h) (3)(ii)(iii)(iv)(v), Page 70268-9, (m) (8), Page 70271] [Page 70252-70253]
New clarifications on state law preemptions and "independent" medical reviews. No preemption for state laws unless prevention of the application of the new regulation [Page 70254] Comply with both the regulation and state laws in claims involving mixed treatment and eligibility determinations and pure medical treatment decision-makings. [Page 70254]
New clarifications with new definitions claim denial/an adverse benefit determination  (payment<100% claimed) or Overpayment, and new protections. (DOL FAQ C-12) Overpayment vs. an adverse benefit determination, recoupment vs. appeal procedures. (DOL FAQ C-12)
SPDs must describe...... No SPDs, No decision making
Insurance company's decision-making power and disclosure obligations must be described in SPD [29 CFR 2520.102-3 (q), Page 70242] Fully-insured plans with a health insurance issuer being wholly or partially responsible for administering the plan (e.g. payment of claims) must describe insurer's role in SPD. [29 CFR 2520.102-3 (q), Page 70242]
Claim fiduciary, whoever makes denial appeal decisions, has duties to disclose SPD and relevant document [29 CFR § 2560.503-1 (h)(2)(iii), (3)(iii) Page 70268-9, (m) (8), Page 70271] or may face up to $110 a day penalty under "Prudent Actions by Plan Fiduciaries" and "Enforce Your Rights."  [29 CFR § 2520.102-3, Page 70243]  Claim fiduciaries or plan fiduciaries have new duties to disclose, without charge, SPD and relevant document [29 CFR § 2560.503-1 (h)(2)(iii), (3)(iii) Page 70268-9, (m) (8), Page 70271] when claim for benefits is denied or delayed, or may face up to $110 a day penalty under "Prudent Actions by Plan Fiduciaries" and "Enforce Your Rights." [29 CFR § 2520.102-3, Page 70243] 
Failure to timely make benefit determination and review decisions by the plan administrator will constitute "deemed denied" review/appeal and "deemed exhaustion of administrative remedy" under § 2560.503-1(l), ("a decision on the merits of the claim" = de novo judicial review, instead of deferential judicial review) that will forfeit or preclude the plan from "deferential review standard" on judicial review in federal court, the most important part of "ERISA Shield" on ERISA land Gilbertson v Allied Signal Inc

DOL interprets § 2560.503-1(l) through CFR accompanying supplementary information on page 70255: “The Department’s intentions in including this provision in the proposal were to clarify that the procedural minimums of the regulation are essential to procedural fairness and that a decision made in the absence of the mandated procedural protections should not be entitled to any judicial deference.”

More.... More....


And many more new and important provisions and protections for health-care providers and insurance companies/ERISA plans/TPA's, as well as patients and employers.






    Due to the recent demand from the ERISA plans and TPA's, we're pleased to announce that we also provide educational and consulting services to the ERISA plans, TPA's and managed care organizations on New Federal Claim/ERISA Regulations and Compliance, however we do not provide any services involving actual claim dispute or legal advice for any legal matter or disputes.

DOL Compliance Assistance for Health Plans




Statutes (United States Code) 
ERISA - Title 29, Chapter 18. 

        Selected links:

Sec. 1002.

Sec. 1003.

Sec. 1022.
Summary plan description
Sec. 1104.
Fiduciary duties

Sec. 1140.
Interference with protected rights

Sec. 1141.
Coercive interference

part 7
group health plan requirements



Code of Federal Regulations

Codified in Title 29 of the Code of Federal Regulations:


        Selected links:

2520.102-3 Contents of summary plan description.

Claims procedure.




ERISA Laws/Rules



#000000; font-weight:normal; font-style:normal">


New HIPAA Privacy and ERISA Claims Review Rules: 10 Reasons To Comply (Brown Rudnick Berlack Israels L.L.P.)

Group Health Plan Compliance with ERISA and HIPAA: Navigating the Legal and Administrative Maze (PDF) (Brown Rudnick Berlack Israels L.L.P.)

72 pages. A 'Question and Answer Resource Guide."



Report of the ERISA Advisory Council's Working Group on Fiduciary Education and Training (U.S. Department of Labor, Employee Benefits Security Administration)

Excerpt: "We strongly urge anyone interested in the issue of fiduciary education to read through the transcripts of our work group's hearings ..."


Fact Sheet - What To Do If Your Health Coverage Can No Longer Pay Benefits


Questions and Answers: Recent Changes in Health Care Law (PDF)


Continuation of Health Coverage – COBRA


HIPAA Nondiscrimination Requirements Frequently Asked Questions



HHS Press Release:

2004.02.19: Text of Letter From Tommy G. Thompson Secretary of Health and Human Services To Richard J. Davidson, President, American Hospital Association.  

HHS FAQ "Questions On Charges For The Uninsured" (PDF)

HHS FAQ's "regarding offering discounts to the uninsured" (PDF)



National Correct Coding Initiative Edits - Version 11

National Correct Coding Edits for the Hospital Outpatient PPS - Version 10.3

2003 Improper Medicare Fee-for-Service Payments Report


CMS Announces Revisions to Payment for Drugs and Physician Fee Schedule Payments for Calendar Year 2004


Medicare Announces 2004 Physician Fee Schedule and Payment Policy Changes

CMS Files for Download for Medicare Payment Systems


CMS Finalizes Appeals Process for Medicare Coverage Decisions


2003.12.10: HHS Announces Immediate Steps to Make Medicare-Approved Drug Discount Card Programs Available Next Spring


42 CFR Parts 403 and 408
Medicare Program; Medicare Prescription
Drug Discount Card; Interim Rule and Notice (pdf) (89 pages)


Revision of Billing Instructions for Purchased Services

Regional Offices Link

2004 Medicare Payment Information Available from CD-Rom (WPS, WI,MI,IL, MN)





BCBS Healthcare Cost Studies Research

BlueCard Delivers National Clients, Admin. Revenues for Blues Plans


NASCO Works With Blues Plans To Increase Large Local Accounts

Welcome To NASCO


Two Blues Giants' Enrollment Gains Show More Americans Are Turning Blue


Most Blue Cross Blue Shield Plans Predict Significant Managed Care Growth in 2003


Google Search: Bluecard program Fiduciary


Google Search: Bluecard program ASO






Aetna Reports Fourth Quarter and Full-Year 2003 Results; 2004 operating earnings guidance increased to between $6.25 and $6.3.


WellChoice 10K SEC

View as HTML

WellChoice 10-K Form


Larry Glasscock, Chairman, President and CEO (PDF)

Investor Presentation

View as HTML


Summary of ANTHEM INC - Yahoo! Finance


Summary of WELLCHOICE INC - Yahoo! Finance


Blue Cross Blue Shield Plan Administrative Expenses Approximate 11% of Premiums, According to Sherlock Company


1199SEIU National Benefit & Pension Funds - SPDs





Employee Book of Benefits


Blue Cross Blue Shield of Michigan United of Omaha Major Medical for UM


View as HTML


BCBSMT Utilization Review




Medical Policy



View as HTML




Blue Cross and Blue Shield System Marks 9th Consecutive Year Of Enrollment Growth (05/17/2004,Blue Cross Blue Shield Association)

ERISA vs Non-ERISA Identification on cards (pdf)   View as HTML


Insurance CEOs are in the money ... AMNews: May 3, 2004.


Hospital CEO salaries show modest increase ... AMNews: Nov. 3, 2003.


AMNews through  AMA

Health plans subject to new federal appeals rules
Much-postponed regulations offer patients and doctors fairer and faster review, plus new rights, Dept. of Labor says.


ERISA Not Insurance

Aetna Video Shows ERISA Patients Mistreated


"According to the video, when faced with claims for identical medical problems, Aetna separates the claims where no damages are available - those subject to the federal Employee Retirement Income Security Act, or ERISA - from non-ERISA claims, where consumers can sue.1 2"


Aetna Reaches Agreement with Physicians, May 22, 2003 (



Managed Care and Patients' Rights
(JAMA Editorial)


$10,600 ERISA Claim

Recent Federal Court Ruling in a Case with $10,600 medical claim, insurance Co. refused to pay, provider made numerous demand for payment in almost one year, but no appeals filed, the court dismissed the lawsuit because provider failed to exhaust administrative remedy, as required under ERISA, by filing ERISA claim appeals.  This situation is so popular in health-care community.



$37,350 ERISA Claim

Health-care provider alleged medical claims submitted to Aetna for reimbursement, Aetna asserted no receipt of medical claims, no written denials.  Health-care provider failed to present proof of claim submission, claim denial and ERISA claim appeals. This case was dismissed. ERISA health-care claims are handled in federal court, state law is generally not applicable.





"requesting payment of benefits and/or to discuss the matter in further detail" by hospitals are wasting time and money



One Employee, One Shareholder, But ERISA Plan

(Name of the Game for 80 Percent of Health-care Claims in U.S.)

Gilbert v. Alta Health & Life Insurance Co. (11th Cir. No. 01-10829,12/27/01).


NHPF Publications  


NHPF Publications  


NHPF Publications  



2002 Employee Health Benefits Survey (Kaiser Family Foundation)


Survey: Employee Benefits in Private Industry (2000) (U.S. Department of Labor, Bureau of Labor Statistics)


Government Survey: Employee Benefits in Private Industry, 2003 (U.S. Department of Labor, Bureau of Labor Statistics)


Are more workers covered by traditional fee-for-service plans, HMOs, or PPOs?


Definitions of Health Insurance Plans and Other Terms (Federal Government’s Interdepartmental Committee)





DOL Secretary Testifies to Committee About ERISA Enforcement, Compliance Assistance (U.S. Department of Labor, Pension and Welfare Benefits Administration)



Study: Health Insurance Premiums Rose More Than 30 Percent Between 1996 and 2000 (U.S. Department of Health and Human Services, Agency for Healthcare Research and Quality)







Opinion: Cutting Costs in Half Through Better Management is Fantasy But Health Care Debate Is Real (The Hartford Courant)
Excerpt: "If a talk on economics can have a $650 billion throwaway line, Treasury Secretary Paul O'Neill delivered it.... "


"O'Neill insists the problem is not with people, but systems - systems that invite medical errors, systems that penalize health care professionals for making honest mistakes, systems that create the mind-numbing complexity of reimbursement for providers, systems that reward too much treatment and punish efficiency."

 Health Cost Trends Shift

"The study said managed care probably has squeezed out all the savings it can from the nation's health care system and that employers are turning to other familiar devices such as increasing premiums and co-payments to trim their costs"



Independent Medical Review Experiences in California (California HealthCare Foundation)



Health Care Issues Stymie Congress (The Hartford Courant)







Kinder and Gentler: Physicians and Managed Care, 1997-2001 (Center for Studying Health System Change)







Employer Spending on Health Care: 1987-2000 (Employee Benefit Research Institute)


Office for Civil Rights - HIPAA

OCR Guidance Explaining Significant Aspects of the Privacy Rule- December 4, 2002



Health Care Spending Rose 8.7% in 2001, the Fastest Rate in 10 Years, Government Statistics Say


In Largest Increase in 12 Years, Health Care Spending Rose 7% in 2000 ...




Employer Health Benefits: 2002 Annual Survey.(pdf)
Accessibility verified January 30, 2003



National Compensation Survey: Employee Benefits in Private Industry in the United States, 2000 (PDF) (U.S. Department of Labor, Bureau of Labor Statistics)


Government Survey: Employee Benefits in Private Industry, 2003 (U.S. Department of Labor, Bureau of Labor Statistics)




GAO Report: Improvements to Retirement Income Data Needed (U.S. General Accounting Office)

"What GAO Recommends:

The Congress should consider directing Labor to obtain from plan administrators electronic filings of SPDs and summaries of material

modifications and make them publicly available."






Uninsured Reached

45 Million in 2003
US Census Press Releases

"The number of people with health insurance increased by 1.0 million to 243.3 million between 2002 and 2003, and the number without such coverage rose by 1.4 million to 45.0 million."


Income, Poverty, and Health Insurance Coverage in the United States: 2003 (P60-226) new

Health Insurance Data (Source: U.S. Census Bureau)

(10 years on the web)

Benefits cost cited in US hiring slump
Washington Times, DC - Aug 19, 2004




Sourcebook: Covering Health Issues 2004 (Alliance for Health Reform)










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