The employer health reform issues briefs are published on a weekly basis, highlighting the latest updates and changes to the new Reform law and implications for employers. The purpose of these briefs is to:
March 2012 - Brief #30
Uniform Summary of Benefits and Coverage (SBC) forms are coming
Beginning with open enrollment periods starting on or after September 23, 2012, the Patient Protection and Affordable Care Act (PPACA) will require employers to provide enrollees and potential enrollees a six-page form for each health plan it offers.
February 22, 2011- Brief #29
Reporting of Employer Health Coverage
Certain employers will be required to file an annual information return with the IRS certifying whether they offer minimum essential coverage to their full-time employees (and their dependents).
February 15, 2011- Brief #28
Notice of Coverage Options
Employers will be required to give all current employees a written notice of the existence of State Health Insurance Exchanges.
February 1, 2011 - Brief #27
Quality Reporting Requirements
Group health plans, except grandfathered health plans, will be required to satisfy new quality reporting requirements pursuant to standards to be issued by the Secretary of Health and Human Services (HHS).
January 20, 2011- Brief #26
New Plan Summary and Advance Notice of Material Changes
Group health plans will be required to develop, maintain, and distribute to enrollees a new summary of benefits and coverage.
January 12, 2011- Brief #25
Mandatory Automatic Enrollment
Employers with more than 200 full-time employees that are subject to the Fair Labor Standards Act (FLSA) will have to establish an automatic enrollment program for their group health plans.
December 7, 2010 - Brief #24
Special Rules for Mini-Med Plans
The continued viability of “mini-med” plans - characterized by relatively low annual limits on the total dollar value of benefits -will be threatened by certain provisions of the new health reform law.
November 17, 2010 - Brief #23
90-day Limit on Waiting Periods
Group health plans will not be permitted to apply any waiting periods that exceed 90 days.
November 10, 2010 - Brief #22
New Cost-Sharing Limits
Group health plans, except grandfathered health plans, will have to comply with new limits on out-of-pocket maximums and deductibles.
November 3, 2010 - Brief #21
Nondiscrimination Rules for Insured Plans
Employers will no longer be able to maintain insured group health plans that discriminate in favor of highly compensated individuals, unless those plans are grandfathered health plans.
October 26, 2010 - Brief #20
Applying Health Reform to Vision and Dental Benefits
Employers will need to analyze dental and vision benefits to determine if they are subject to the market reforms, or if they are “excepted” health benefits, and take the necessary steps to address changes in plan design.
October 20, 2010 - Brief #19
Changes to Opt-out Provision for Self-insured State and Local Government Plans
Self-insured state and local government group health plans, including grandfathered health plans, will no longer be able to opt-out of certain HIPAA requirements.
October 12, 2010 - Brief #18
W-2 Reporting of Cost of Employer Health Coverage Not Mandatory for 2011
Employers will be required to report the aggregate cost of employer-sponsored health coverage on employees’ Forms W-2.
September 29, 2010 - Brief #17
Special Enrollment Periods for 2011 Plan Years
Group health plans, including grandfathered health plans, may need to offer certain employees and their dependents a 30-day special enrollment opportunity.
September 22, 2010 - Brief #16
Health Saving Account Reimbursements
Provisions for distributions from Health Savings Accounts (HSAs) to pay for a medicine or drug as qualified medical expenses.
September 12, 2010 - Brief #15
Health FSA and HRA reimbursements
Provisions for the reimbursement of medicine or drugs through Health Flexible Spending Arrangements (Health FSAs) and Health Reimbursement Arrangements (HRAs).
September 7, 2010 - Brief #14
External Review Process
What non-grandfathered group health plans must do to comply with the external review requirements, based on guidance issued to date.
September 1, 2010 - Brief #13
Grandfathered Health Plan Status
Keys to understanding the advantages and disadvantages of being a grandfathered health plan, and knowing what actions will and won't result in losing that status.
August 24, 2010 - Brief #12
Wellness Plan Incentives
Group health plans may offer premium discounts or other rewards of up to 30 percent of the cost of employee-only coverage to employees who participate in certain wellness programs.
August 10, 2010 - Brief #11
Patient-centered outcomes research fee
Issuers of health insurance policies to group health plans and sponsors of self-insured group health plans must pay an annual patient-centered outcomes research fee.
August 4, 2010 - Brief #10
Patient protections II - Emergency services
Group health plans, except grandfathered plans, that provide any benefits for hospital emergency services will be subject to new standards.
July 30, 2010 - Brief #9
Communicating Health Reform for the 2011 Plan Year
Group health plans must communicate applicable mandatory notices to employees related to specific provisions of the Patient Protection and Affordable Care Act.
July 30, 2010 - Brief #8
Patient Protections I – Provider Networks and Primary Care Physicians
Group health plans, except grandfathered plans, that require or provide for designating a primary care provider (PCP) will be subject to several new requirements.
July 12, 2010 - Brief #7
Limits on Rescissions of Group Health Plan Coverage
Group health plans, including grandfathered health plans, will not be permitted to rescind coverage except in cases of fraud or intentional misrepresentation of a material fact.
July 6, 2010 - Brief #6
Ban on Annual and Lifetime Limits
Group health plans, including grandfathered health plans, will not be permitted to impose annual or lifetime limits on the dollar amount of certain benefits for any individual.
June 18, 2010 - Brief #5
Internal and External Appeals of Claims Decisions
All group health plans, except for grandfathered plans, must implement an effective process for participants to appeal coverage and other claim determinations.
June 7, 2010 - Brief #4
Ban on Preexisting Condition Exclusions
All group health plans - including grandfathered plans - will be prohibited from imposing any preexisting condition exclusions.
June 7, 2010 - Brief #3
Mandatory Coverage of Preventive Services
Group health plans other than grandfathered plans will be required to cover certain preventive services, and no cost sharing (including deductibles, co-pays, and co-insurance) will be permitted for this coverage.
May, 2010 - Brief #2
Implementing and Communicating Changes to Health FSAs
Beginning Jan. 1, 2013, Health FSAs will be required to limit employee contributions to no more than $2,500 per year (subject to annual inflation adjustments).
May, 2010 - Brief #1
Extension of Dependent Coverage to Age 26
Employer-sponsored health plans will be required to continue covering employees' children up to age 26, regardless of full-time student or marital status.