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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
2010-61
August 4, 2010
Health Care Reform Compliance Dates for Grandfathered
and Non-Grandfathered Self-Insured Group Health Plans
This Client Bulletin
focuses on health care reform compliance dates under the
Affordable Care Act
for grandfathered and Non-grandfathered self-insured group
health plans. Requirements applicable to insured group or individual market health
plans are not included in this discussion.
A grandfathered health plans is one which was in existence on March 23, 2010 and
which has maintained its grandfathered status since then. A Non-grandfathered
health plan is a grandfathered plan that lost its grandfathered status or a plan in
existence after March 23, 2010. A chart showing reforms applicable to each type of
plan is available by “clicking here.” A summary entitled Grandfathered Plan Status
-
How to Keep It or Lose It is available by “clicking here.”
A list of published guidance and other information about the Affordable Care Act is
available at http://www.hhs.gov/ociio/regulations/index.html. A timeline showing
the date of passage of the law and subsequent guidance and the Research
Department publication in which the guidance was discussed is available by
“
The
section below lists reforms applicable to both
grandfathered and Non-
grandfathered group health plans. Grandfathered and Non-grandfathered plans
must comply with the following reforms by the first Plan
Year beginning on or
after September 23, 2010, unless otherwise noted. For calendar year plans, that
is January 1, 2011.
GRANDFATHERED AND NON-GRANDFATHERED PLANS
No lifetime limits on coverage;
Prohibition on “unreasonable” annual limits on essential benefits (3-yr phase-
in allowed under regulations;
No rescissions
of coverage unless
for fraud
(a rescission is a retroactive
cancellation of coverage – prospective cancelations are not rescissions);
CLIENT BULLETIN