Viewing posts from: June 2010

PPACA Regulations – Preexisting Exclusions, Lifetime & Annual Limits and More

Posted June 22, 2010 by admin

Federal Regulators released guidance on several new matters today.

1. DOL/IRS/HHS released new regulations: Patient Protection and Affordable Care Act: Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions, and Patient Protections

These interim final regulations define “essential health benefits” by cross-reference to section 1302(b) of the Affordable Care Act 8 and applicable regulations (which have not been released).

However, for those grandfathered plans, certain annual limits, called “restricted annual limits” may still be possible (check to see if you plan has any annual limits now before contemplating any changes as a result of the chart below). A carrier or group health plan may establish an annual limit on the dollar amount of benefits that are essential health benefits, provided the limit is no less than:

(i) For a plan year beginning on or after 9/23/2010, but before 9/23/2011: $750,000.
(ii) For a plan year beginning on or after 9/23/2011, but before 9/23/2012: 1,250,000.
(iii) For plan years beginning on or after 9/23/2012, but before January 1, 2014: $2,000,000.

Click here for the Federal Register’s PDF.

2. Today, the Department of Labor also released a new Patient’s Bill of Rights.

Fact Sheet: The Affordable Care Act’s New Patient’s Bill of Rights is available here.

Q&A from the DOL: Keeping My Health Plan Grandfathered

Posted June 17, 2010 by admin

During the health reform debate, we heard the mantra “if you like your health plan you can keep it.” The takeaway from that mantra was that if you like your doctor and your coverage you’ll be able to keep it.

The new “grandfather” rules implement the provisions of the Affordable Care Act and enable businesses and families to keep their plan while adding new benefits for others. Here are the DOL’s key questions and answers on the topic: “Keeping the Health Plan You Have: The Affordable Care Act and ‘Grandfathered’ Health Plans.” And, as always, employers/plan sponsors should consider, in coordination with thoughtful consultation with their Sales Executive and Account Manager, what ramifications (costs) will there be, if any, for losing the “grandfathered” status.

DOL’s Q&A
Crawford’s Reform Timeline for Employers
DOL’s Grandfathered Regulation Table
DOL’s Model “Grandfathered Plan” Notice
(to be distributed on/before the 1st day of the 1st plan year after 9/23/2010)

Keeping the Health Plan You Have: The Affordable Care Act and “Grandfathered” Health Plans

Posted June 14, 2010 by admin

Today, the Internal Revenue Service, Department of Labor and the Department of Health and Human Services released their “Final Interim Rules” to inform, assist and otherwise help group health plans comply with certain requirements of the new health care reform laws.

Current plans are permitted to make some changes, while other changes would cause them to lose their “grandfathered” status. Examples include the following (as compared to plan specifications that were in place on 03/23/2010):

  1. A grandfathered plan would lose its status if it eliminated coverage of a specific condition (the rules cite diabetes, HIV/AIDS and cystic fibrosis as examples).
  2. Coinsurance percentages cannot change.
  3. Copayments cannot be increased by more than, the greater of $5 or a percentage equal to medical inflation plus 15%.
  4. Cannot Significantly Raise Deductibles. Limit is equal to medical inflation plus 15%.
  5. Cannot Significantly Lower Employer Contributions (conversely cannot significantly increase Employee Contributions). Grandfathered plans cannot decrease the percent of premiums the employer pays by more than 5 percentage points (for example, decrease their own share and increase the workers’ share of premium from 15% to 25%).

The DOL’s fact sheet can be found here.

The full regulations (the Interim Final Rule) can be found here.

DOL’s Model “Grandfathered Plan” Notice
(to be distributed on/before the 1st day of the 1st plan year after 9/23/2010)

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