PPACA Update: Certificates of Creditable Coverage
Affects all plans, whether fully insured, self-funded or grandfathered, and regardless of employer size, as of Jan. 1, 2015. Because pre-existing condition limitations will not be permitted after the start of the 2014 plan year, certificates of creditable coverage would not need to be provided after Dec. 31, 2014. (This date would apply regardless of […]
PPACA Update: Eligibility Waiting Periods
Affects all plans, whether fully insured, self-funded or grandfathered. Applies to all sizes of employers, as of the start of the 2014 plan year. The agencies have issued proposed regulations that state that an eligibility waiting period cannot be more than 90 days. This literally is 90 calendar days — a plan that begins coverage […]
PPACA Employer Fees: Patient-Centered Outcomes Research Institute (PCORI) and Transitional Reinsurance (TRF)
The IRS and the Department of Health and Human Services have issued final regulations that provide details on two new, temporary fees that will be due as part of the Patient Protection and Affordable Care Act (PPACA). These fees will be calculated and paid directly by self-funded plans. The fees will be calculated and paid […]
Play or Pay: Non-Calendar Year Transition Rules for Measuring in 2013
A non-calendar year plan that had coverage in place on Dec. 27, 2012: Will not owe the “inadequate coverage penalty” on any employee who was eligible for coverage on Dec. 27, 2012 (and on employees hired after that date, if they would have been eligible under the rules in effect on that date) until the […]
Final Regulations Issued on Market Reforms-Fair Health Insurance Premiums for Fully Insured Health Care Plans
Impacts all non-grandfathered fully insured small group plans (both in and outside the exchange) beginning with the 2014 plan year: The changes in the rules that apply to fully insured small groups, whether the coverage is provided inside or outside the exchange, are significant. From an employer standpoint, the most significant change probably is that […]
Final Regulations Issued on Market Reforms-Guaranteed Access for Fully Insured Health Care Plans
Impacts all nongrandfathered fully insured plans, whether inside or outside the exchange, beginning with the 2014 plan year: Guaranteed issue and renewal will apply to all insured plans regardless of size. Participation and employer contribution requirements will not be permitted under the guaranteed availability rules, although insurers may impose participation and employer contribution requirements at […]
Final Regulations Issued on Essential Benefits and Actuarial Value for Fully Insured Health Care Plans
Impacts non-grandfathered small-group plans (both in and outside the exchange) beginning with the 2014 plan year: Beginning with the 2014 plan year all nongrandfathered plans in the small group market – whether inside or outside the exchange – will need to provide the “essential health benefits package” (EHB package). The EHB package includes coverage for […]
FAQ Released: Final Regulations Issued on Minimum Value for Fully Insured Health Care Plans
Impacts large fully insured plans with 50 or more employees: Large group insured plans are not required to provide the ten “essential health benefits” or coverage at a “metal level” as small plans will be required to do. (The essential health benefits are coverage within these categories – ambulatory/outpatient, emergency, hospitalization, maternity and newborn care, […]
FAQ Released: Final Regulations Issued on Minimum Value for Self-Funded Health Care Plans
Impacts all self-funded plans as of the start of the 2014 plan year Self-funded plans (regardless of size) will not be required to provide the ten “essential health benefits” or coverage at a “metal level” as some plans will be required to do. (The essential health benefits are coverage within these categories – ambulatory/outpatient, emergency, […]
COMPLIANCE ALERT: Labor Department Releases New FMLA Model Forms and Notice Poster
The U.S. Department of Labor has released revised model Family and Medical Leave Act (“FMLA”) forms to administer federal FMLA leave and a notice poster. The updated forms should be used by employers immediately, although they include no substantive revisions despite recent rulemaking on the FMLA military caregiver leave provisions (see our article DOL Publishes […]