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Prepared for TIC by Mike Ewing, J.D.
Director of Research
United Actuarial Services, Inc.
(317) 580-8659
Fax (317) 580-8651
email: mewing@unitedactuarial.com
© United Actuarial Services, Inc. 2010
2010-30
April 20, 2010
Health Reform Law –
A Simple Look At Upcoming Compliance Dates
Updated DOL COBRA Fact Sheet
In this Client Bulletin
we will take a simple look at upcoming compliance dates of
interest to group health plans, including multiemployer health plans. For prior
we discussed in detail the retiree reinsurance program and the difficulty in
determining the impact of the “delayed” effective date for health plans established
under collectively bargained plans, and the idea of “grandfathered plans.” We still
hadn’t tied up the near-term changes in a nifty compliance chart - until this issue.
Our discussion of compliance dates will assume a group health plan on existence as
of the date of the passage of the PPACA
is
a “grandfathered” plan. REMEMBER
MANY DETAILS ARE UNCLEAR
AND NO ONE WILL REALLY KNOW ALL THE
ANSWERS UNTIL GUIDANCE IS ISSUED…
The following reforms are generally effective for Calendar Year plans the first
plan
year beginning on or after October 1, 2010, or January 1, 2011. The dates below
DO NOT take into account any possible delayed effective date for collectively
bargained plans. Check with fund counsel for their opinion on the CBA delayed
effective date. Don’t be surprised if
most are waiting for clarification from Health
and Human Services (HHS).
Compliance Dates
January 1, 2011 - Calendar Year Plan Changes Effective Date
Prohibition on lifetime maximums.
Plans may wish to evaluate stop-loss coverage.
Prohibition on “unreasonable” annual limits on essential benefits.
HHS will determine what is included in “essential benefits.” Plans may wish
to evaluate stop-loss coverage.
CLIENT BULLETIN