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 […]

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-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 […]

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 […]

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