Comment Letters Archive

The Church Alliance writes and distributes comment letters, memoranda and other materials regarding laws and regulations that impact church retirement and health benefit plans. Topics include:

Health Care Comment Letters and Additional Materials

Comment Letter—Proposed Rule on Patient Protection and Affordable Care Act: Establishment of the Multi-State Plan Program for the Affordable Insurance Exchanges (January 4, 2013)
From the Church Alliance to the U.S. Office of Personnel Management (OPM) commenting on how the OPM has sufficient discretion under the Multi-State Plan Program (MSPP) of the Patient Protection and Affordable Care Act (PPACA) to permit church health plans to provide coverage to their participants through the MSPP on the ACA’s health insurance exchanges.

Comment Letter—Exchange Regulations (October 31, 2011)
From the Church Alliance to HHS arguing that under the language of the ACA, the Departments have the discretion to permit church health plans to become qualified health plans and operate on the ACA’s health insurance exchanges through a federally-established exchange.

Comment Letter—Summary of Benefits and Coverage (October 21, 2011)
From the Church Alliance to HHS explaining the difficulties for church health plans under the proposed rule for the requirement that health plans use a uniform summary of benefits and coverage to describe benefits to covered participants.

Comment Letter—Contraceptive Religious Employer Exemption (September 28, 2011)
From the Church Alliance to HHS urging a broader definition of “religious employer” for purposes of the exemption from the contraceptive coverage mandate under the ACA’s preventive services coverage rule.

Church Alliance Small Business Health Care Tax Credit Summary (January 6, 2011)
Memorandum from the Core Lawyer Working Group for Church Alliance and Church Benefits Association member denominations explaining the impact of the Small Business Health Care Tax Credit on church employers.

Comment Letter—Grandfathered Plan Regulations (August 10, 2010)
From the Church Alliance to HHS explaining the difficulties for church health plans under the interim final rule for grandfathered plans under the ACA.

Church Alliance Letter to ACA Regulators (June 16, 2010)
From the Church Alliance to the White House, Department of Labor (DOL) and Department of Health and Human Services (HHS) regarding a meeting of stakeholders about the grandfathered plan rule under the ACA.

Comment Letter—Section 45R Small Business Health Care Tax Credit (May 13, 2010)
From the Church Alliance to the Internal Revenue Service (IRS) arguing, based on the language of the Patient Protection and Affordable Care Act (PPACA or ACA) and the nature of church plans, that the Small Business Tax Credit should be available to small employers in self-insured church health plans.

 


 

Retirement Security Comment Letters and Additional Materials

Church Alliance House Ways and Means Working Group Statement (April 15, 2013)
The Church Alliance submitted a statement to the U.S. House of Representatives Ways and Means Committee Tax Reform Working Group on Pensions/Retirement on April 15, 2013. The Church Alliance urges the House Ways and Means Committee to consider policies that strengthen church retirement plans and protect their participants. The statement asks the House Ways and Means Committee to consider the provisions of the “Church Plan Clarification Act,” which was introduced as S. 3532/S. 143 and as part of H.R. 4050 in the 112th Congress, and makes necessary technical corrections to federal laws governing church retirement plans.

 


 

Financial Services Comment Letters and Additional Materials 

CFTC Memo—Church Plan Special Entity Definition (October 4, 2011)
Following a meeting on September 9, 2011 between representatives of the Church Alliance and the Commodity Futures Trading Commission (CFTC), this memorandum discusses the issue of how to classify “church plans” for purposes of various regulations under the Dodd-Frank Act.

CFTC Memo: Church Plans—Definitions and Legislative History (October 4, 2011)
Memorandum on church plan definitions and legislative history, steming from a September 9, 2011 meeting between representatives of the Church Alliance and the Commodity Futures Trading Commission (CFTC).

Follow-up Letter—CFTC (October 4, 2011)
From the Church Alliance to the CFTC after in-person meeting with CFTC Commissioners and staff about the business conduct standards rule, with accompanying memos explaining church plan and church benefit boards definitions and proposing an opt-in provision for church plans with respect to “special entity status.”

Comment Letter—SEC Business Conduct Standards (August 29, 2011)
From the Church Alliance to the Securities and Exchange Commission (SEC) urging treatment of church plans and church benefit boards as “special entities” under the business conduct standards rules for swap dealers under the Dodd-Frank Act.

Comment Letter—CFTC Swap Definitions (February 22, 2011)
From the Church Alliance to the CFTC urging exclusion of church plans and church benefit boards from the being considered a “swap dealer” and “major swap-based participant” under the Dodd-Frank Act.

Comment Letter—CFTC Business Conduct Standards (February 22, 2011)
From the Church Alliance to the Commodity Futures Trading Commission (CFTC) urging treatment of church plans and church benefit boards as “special entities” under the business conduct standards rules for swap dealers under the Dodd-Frank Act.