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 …
Information Collections & Claims Procedures
March 10, 2011 Leave a Comment
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 …
Top 5 Health Care Reform Issues Employers Should Focus on Today
March 3, 2011 Leave a Comment
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 …
New Non-Discrimination Rules Delayed
January 27, 2011 Leave a Comment
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 …
Grandfather Relief for Insured Plans
November 17, 2010 Leave a Comment
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 …
Additional Guidance on Grandfathered Status
October 15, 2010 Leave a Comment
We’ve previously discussed grandfathered status in alerts and webcasts. Generally, employers that want to maintain grandfathered status are restricted in the changes that can be made to a health plan as it existed on March 23, 2010. The latest guidance, more FAQs, clarifies how some of the requirements to …