The Departments of Health and Human Services, Labor and the Treasury recently issued another set of frequently asked questions (FAQs) regarding grandfathered health plans under the Patient Protection and Affordable Care Act (PPACA).
The most recent set of FAQs
addresses how the grandfathered status of a health plan will be affected by transferring employees from a benefit package that is being eliminated into another benefit package; the price fluctuations of medication due to a generic alternative entering the market; value-based insurance design related to preventive services; changes to a plan in the middle of a calendar year; and employer contributions into a plan for retirees.
Five other sets of FAQs related to PPACA have been released since September 2010 with more expected in the future.
- A set of FAQs released in March addresses market reform provisions; the Mental Health Parity and Addiction Equity Act of 2008; automatic enrollment requirements; notice requirements for material modifications to a plan or coverage; and wellness programs, grandfathered health plans, dependent coverage, preexisting condition exclusions for children, and disclosure requirements.
- A set issued on Oct. 29, 2010 clarifies how often grandfathered health plans are required to disclose their status to enrollees and what would cause a plan to lose its grandfathered status, in addition to clarifying the “essential health benefits” requirement.
- An Oct. 12, 2010 document addresses the exemption for group health plans with less than two current employees.
- A set of FAQs released Oct. 8, 2010 addresses questions related to grandfathered health plans; dental and vision benefits; rescissions; preventive services; and contains a clarification relating to policy years and the effective date of PPACA for individual health insurance policies.
- A Sept. 20, 2010 set of FAQs addresses compliance; grandfathered health plans; claims; internal and external reviews; dependent coverage of children; out-of-network emergency services; and highly compensated employees.
More information is available on the DOL website: http://www.dol.gov/ebsa/healthreform/index.html