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Health Care Reform Updates
At USI Affinity, we follow the changes in Health Care Reform very closely and make sure that all of our clients are up to date on the issues. Check back periodically as we will update this page with important information regarding health reform and its impact on your business.
Departments Release New Health Care Reform FAQs
The Departments of Labor, Health and Human Services and the Internal Revenue Service (collectively, the Departments) issued two new sets of frequently asked questions (FAQs) that provide some much needed clarification on the market reforms contained in the Patient Protection and Affordable Care Act (PPACA).
Health Care Reform Implications for Employers with Seasonal Employees
Many industries (e.g. ski resorts, retail, restaurants, agriculture, fishing and tourism) have a significant number of seasonal employees.These employees are hired by the employer to work for a limited period of time, typically during the employer’s “busiest” season.
Health care reform legislation passed earlier this year will have significant impacts on individuals and employers. This is particularly true for employers with a seasonal employee population. While many of the requirements are not effective until 2014, this summary is intended to highlight some key points for employers with a seasonal workforce to consider when developing a long-term benefits strategy. It is not an exhaustive analysis and further guidance is needed on many of these issues.
Regulations Issued Addresing Claims and Appeals Procedures
The Departments of Labor, the Treasury and Health and Human Services issued an interim final rule for group health plans and health insurance carriers relating to internal claims and appeals procedures and external review processes under the Patient Protection and Affordable Care Act (PPACA).
Final Interim Regulations Released on Preventive Care
As reported earlier, effective for the first plan year that begins on or after September 23, 2010, a group health plan and a health insurance carrier must (at a minimum) provide coverage for and must not impose any cost sharing requirements on preventive items and services. This requirement does not apply to grandfathered coverage.
On July 14, 2010, final interim regulations were issued which:
- list required preventive items and services;
- make clear that the new rules only apply to in-network benefits; and
- provide that cost-sharing can still apply in certain circumstances where the preventive item or service is provided during an office visit but is not separately accounted for and is not the primary purpose of the visit.
The regulations are available at http://www.healthcare.gov/center/regulations/prevention/regs.html.
Departments Issue Further Guidance on Health Care Reform
The Departments of the Treasury, Labor and Health and Human Services (collectively, the Departments) issued final interim regulations addressing many of the new consumer protections contained in the Patient Protection and Affordable Care Act (PPACA), including the restrictions on lifetime and annual limits on “essential benefits.”
The regulations are effective August 27, 2010 and generally apply to plan years beginning on or after September 23, 2010 (unless otherwise noted in this summary).
This release discusses the regulations as they pertain to an employer-sponsored group health plan. Specifically, it addresses guidance that applies to all group health plans (grandfathered and non-grandfathered) and specific patient protections that apply to non-grandfathered group health plans.
Grandfathered Plan Regulations Released
The Departments of Labor, Health and Human Services and the Treasury (collectively, the Departments) issued interim final rules addressing grandfathered status under the recently enacted Patient Protection and Affordable Care Act (PPACA). The regulations are effective for the first plan year that begins on or after September 23, 2010.
This guidance provides some much needed clarification, particularly as it relates to what a plan can and cannot do in order to retain grandfathered status. The following summarizes the rule in a question and answer format.
Small Business Health Care Tax Credit
Health coverage legislation enacted this year includes a Small Business Health Care Tax Credit to help small businesses and small tax-exempt organizations afford the cost of covering their workers.
Health Care Reform Timeline for Employer Compliance
This timeline provides some of the key dates associated with the recently enacted health care reform legislation.
2010 - Immediate Reforms
March
- Plans in existence on or before March 23, 2010 are considered grandfathered.
June
- Retiree-plan Assistance A temporary government reinsurance program for employer-provided retiree (age 55-64) benefits. May reimburse up to 80% of the cost of claims between $15,000 and $90,000. Effective June 21, 2010.
- Small Business Tax Credits Tax credits for small business (no more than 25 employees and average annual wage of no more than $50,000). Up to a 35% tax credit when the employer contributes at least 50% of the premium costs.
Age 26 Dependent Guidance
The various agencies charged with implementing health care reform have issued interim final regulations on the extension of dependent coverage to young adults up to age 26. The guidance fills in some of the gaps as to how this new rule will work, but still leaves some issues yet to be resolved.
The new guidance is timely, given the efforts of the Secretary of Health and Human Services to encourage insurers to offer this coverage earlier than required by the law.
Health Reform - What it will mean for you
The President signed the Senate health care reform measure,the Patient Protection and Affordable Care Act (H.R. 3590), into law on March 23, 2010. Companion legislation, the Health Care and Education Affordability Reconciliation Act of 2010(H.R. 4872), was just approved in the Senate by a vote of 56 to 43. Before the companion bill can be enacted, the House must take a final vote on the legislation, as certain features related to student loans were struck by the Senate Parliamentarian. The House is expected to move quickly to pass the revised legislation. It will then go to the President for signature.