Technical Corrections & Regulations
How will errors, oversights, and omissions found in H.R. 3103 be addressed? What actual steps will bring about amendments and clarifications of H.R. 3103? Are corrections and amendments expected in the remaining weeks or the 104th Congress or must they await the first session of the 105th Congress in early 1997?
Will a technical amendments (corrections) bill be issued in regard to H.R. 3103? If so when can it be expected?
The technical corrections to H.R. 3103 will be an ongoing process. While the congressional calendar for the remainder of this session does not include a specific technical corrections bill at this time, we will continue to provide a great deal of input on needed corrections. We have shared similar comments with Chairman Archer and expect to be included during the regulatory process. Much of this will occur simultaneously after the regulations are first drafted.
The Departments of Labor, Treasury, and HHS will promulgate regulations implementing H.R. 3103. Will all regulations first appear in the Federal Register prior to implementation?
Will public comment be solicited and acted upon or waived?
What will be the timing and schedule for issuance of regulations?
Will the sections and names of individuals responsible for each regulation be known and publicized? Can we expect any inter-agency coordination prior to issuance of regulations?
Will private sector interests work together on the regulations and their effects?
What regulatory qualifications/reporting requirements will be in place?
We expect that the appropriate departments will promulgate regulations required by the bill. Some of the regulations will require coordination between departments. Interested parties may offer input during this part of the process, as well as during the comment period. When regulations have been drafted, they will be submitted to Chairman Archer who will comb through the proposed regulations to make sure they reflect the intent of the law (H.R. 3103). Chairman Archer will consult with experts in the industry on the regulations, presenting another opportunity for private sector interests to have input. After he approves the regulations, they will be sent back for publication in the Federal Register. We have been told that there will be only a 30-day comment period on the regulations before they are finalized. CAHI is in continual contact with Chairman Archer's staff on regulatory and technical correction issues.
Have any first drafts of regulations come out of IRS/Treasury, Labor yet? Any notions as to intent and directions they are taking?
We have been in contact with several people drafting regulations. While there are indications of interpretations of the law that differ from the intent of those who drafted the legislation, these are few and probably manageable. Those who passed the legislation have a commitment to approving regulations that meet the intent of the law.
How will reporting be formatted, especially dates, deadlines, and penalties?
Many details such as these will be covered in the regulations, which have yet to be written. Specific suggestions regarding such matters may be given directly to those involved in the regulatory process (who have yet to be identified), or forward to CAHI. We will collect suggestions and present them as a body to the proper agency personnel.
[3103 Q&A Index]
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