New Agency FAQ Provides Grandfathered Plan Guidance

The latest health care reform implementation FAQ Part VI provides further guidance on grandfathered health plans. We have been closely following the agencies’ discussions of grandfathered status, such as the interim final regulations released last June and the prior FAQ issued last October. The new …

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Enforcement Grace Period Extended for New Internal Claims and Appeals Requirements

The Department of Labor has further delayed enforcement of the new requirements for internal claims and appeals that apply to non-grandfathered plans. Technical Release 2011-01 extends and slightly modifies the enforcement grace period that was set to expire on July 1, 2011 under Technical Release 2010-01.  The …

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Information Collections & Claims Procedures

The DOL is requesting comments on the “information collections” that are imposed on non-grandfathered group health plans by the claims and appeal regulations under health care reform. The request, published on March 1, notes that these information collections are part of the “reasonable procedures that an …

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Top 5 Health Care Reform Issues Employers Should Focus on Today

It has now been almost a year since health care reform was first enacted. The first year involved many compliance challenges, not the least of which was keeping up with the many pieces of guidance issued by the Department of Labor, Internal Revenue Service and Health and Human Services. But now that the first …

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New Non-Discrimination Rules Delayed

Fully-insured group health plans need not comply with the new non-discrimination rules until further notice, according to IRS Notice 2011-1, released in late December. Under health care reform, non-discrimination rules “similar to” those in Code Section 105(h)—which currently only apply to self-funded …

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Grandfather Relief for Insured Plans

An amendment to the grandfather regulations allows insured plans to change insurance carriers without losing grandfather status. We’ve discussed the limits and effects of grandfather status in several other posts and a webcast. In general terms, if an existing plan significantly reduces benefits or increases …

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