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How does OPM intend to work with States on form filing and review for MSPP issuers?

MSPs will be subject to Federal and State laws with respect to benefit plan material or information, including requirements at proposed 45 C.F.R. § 800.113. Although OPM intends to review and approve policy forms for health insurance coverage, OPM expects MSPP issuers to comply with related State law requirements for policy form review. OPM expects that that few disagreements will arise between OPM and a State regarding policy form review and, if they do, that we will be successful in resolving them in a manner that is acceptable both to OPM and the State at issue. OPM intends to work closely with each State in reviewing forms for the MSPs in that State and will consult with that State as appropriate to ensure that the MSPs are not disruptive to markets.

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