Benefits Think Proposed regulations clarify TIN responsibilities, create new questions

Published August 11, 2016 1:05 PM EDT 12 Min Read

The initial solicitation is made at an individual’s first enrollment or, if already enrolled on September 17, 2015, the next open enrollment;
The second solicitation is made at a reasonable time thereafter, and
The third solicitation is made by December 31 of the year following the initial solicitation.

General Counsel

Moulder serves as general counsel at Accord Systems, LLC and is a partner at Health Care Attorney's P.C. He received his LL.M. from Georgetown University Law Center and his J.D. from Saint Louis … Read full bio

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