Internal Revenue Code Section 105(h) describes non-discrimination rules that apply to self-funded group health plans. PPACA extends the Section 105(h) non-discrimination requirements to non-grandfathered fully-insured group health plans. Unfortunately, even though Section 105(h) was added to the Code in 1978, …
Annual Enrollment Materials and Welfare Notices
September 30, 2010 Leave a Comment
You may be preparing materials and notices for an upcoming annual enrollment period. Health care reform and other recent laws have added or changed several notices that are required before the next plan year starts (1/1/2011 for calendar-year plans). The agencies have provided several model notices to assist with …
Implementing External Review Processes
September 29, 2010 Leave a Comment
Non-grandfathered group health plans must soon implement external review processes for benefit claim determinations. Our recent Benefits Alert discusses the new agency guidance on how external reviews should work—and how plans can get a little relief. Today's post was contributed by Jessica Faith. …
Six Months And Counting
September 28, 2010 Leave a Comment
You have probably heard a lot about the health care reform provisions that “went into effect” last week. To clarify, these provisions are effective for plan years beginning on or after September 23, 2010; for calendar-year plans, the rules will not apply until January 1, 2011. Grandfathered plans are exempt …
DOL Releases FAQs on Health Care Reform
September 21, 2010 Leave a Comment
The DOL released Frequently Asked Questions on September 20, 2010 which address several open questions on health care reform: For adult child coverage requirements, we’ve received many questions about the definition of child. This guidance answers some of those questions. A plan will not fail to satisfy the …
Comments on “Grandfathered” Plan Regulations
August 16, 2010 Leave a Comment
Although the interim final regulations implementing the “grandfather” provisions of PPACA that were released on June 17, 2010, provided some guidance on what types of changes to a grandfathered plan would result in loss of grandfathered status, many questions remain for plan sponsors currently trying to decide …