On October 19, 2015, the Centers for Medicare and Medicaid Services (CMS) released a series of frequently asked questions explaining how it will implement the PACE Act. States may elect to extend the definition of small employer to cover employers with up to 100 employees by any means that is legally binding under state law, as long as the definition applies to all insurers, including those in the Small Business Health Options Program (SHOP) program. States that elect to expand the definition as of January 1, 2016 are requested to notify CMS by October 30, 2015.
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