Comments were due in mid-September regarding the interim final regulations on preventive care requirements. Under the preventive care requirements, non-grandfathered group health plans must provide first-dollar coverage for the following: Evidence-based items or services with a rating of A or B in the …
RAC Medical Necessity Denials Are On Their Way
October 15, 2010 Leave a Comment
On August 6, 2010, CMS gave its approval to CGI, the Recovery Audit Contractor (RAC) for Region B, to review the medical necessity of inpatient admissions. Other RAC contractors followed suit shortly thereafter. One of the specific issues approved relates to the medical necessity of an inpatient admission for …
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 …
W-2 Relief for 2011
October 13, 2010 Leave a Comment
We previously blogged about the new Form W-2 requirement under health care reform. Health care reform technically requires disclosure of the cost of coverage effective for 2011 Forms W-2. But the IRS just issued relief for reporting health care coverage in 2011 and will not impose penalties for failure to do …
Clarification on Rescissions
October 12, 2010 Leave a Comment
As we mentioned recently, the agencies are issuing additional guidance in the form of Frequently Asked Questions. The most recent of these FAQs answer a few of the questions we had raised in an earlier post. Today’s post will discuss the guidance on rescissions. Plan sponsors and administrators will be happy to …
Guidance on Non-Discrimination Rules for Insured Plans
October 11, 2010 Leave a Comment
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, …