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Employee premium contributions are considered ERISA plan assets, although the Department of Labors longstanding position is that these amounts do not have to be held in trust or otherwise segregated from the plan sponsors general assets, even if the plan is self-insured.[iii] These funds still must be used to pay benefits or reasonable plan administration expenses, but this typically is not an issue because the amount of claims that are also being paid from the plan sponsors general assets usually will exceed the amount of premium contributions being collected from employees

The system rewards offshoring and complex supply chains, distorting the market at taxpayer expense

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