To all who responded:
These are great responses. To put them all together into a coherent thought, the 'averaged' response was:
" No they are not permitted to decline 834 transactions as of the October deadline. However, it is unclear that going through the remedy process will bring them into compliance quickly, as they are probably dealing with thousands of partners (overwhelming) and could show a reasonable compliance plan. It would be prudent to advise this client (plan sponsor) to prepare himself for the 834 in case one of his carriers asks him to submit his enrollment/maintenance information electronically."
Does the preceding paragraph sound OK and realistic?
Glenn Dekhayser
Vice President, Technology
Voyant Strategies, Inc.
732-335-1500 x514
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