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Will MSPs and MSPP issuers be required to comply with all State laws?

The Affordable Care Act generally requires that MSPs and MSPP issuers comply with all State and Federal laws that apply to QHPs and QHP issuers. However, the Affordable Care Act also grants discretion to the Director to administer the MSPP in a manner that fulfills OPM’s statutory responsibility under section 1334 of the Affordable Care Act. OPM intends to administer the MSPP in a manner that achieves the objectives of the law.
It is not possible at this time to identify with specificity the laws that will apply to QHPs and QHP issuers. Therefore, it is not possible to identify any law that OPM deems to be inconsistent with section 1334 of the Affordable Care Act, our proposed regulations, OPM guidance, or OPM’s contracts with MSPP issuers.

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