Argus Alert April 19/10
Health Care Reform…What’s Next?
Health care reform is now a reality. The Patient Protection and Affordable Care Act and its companion bill, the Health Care and Education Reconciliation Act were signed in to law in late March, 2010. Together, these bills are referred to as the Federal Health Care Reform Law. While there may be legal challenges for this legislation, it is now law and it is imperative that employers have a detailed understanding of the changes, both immediate and future, so that they may plan and account for the administrative and financial impact of these changes to their business.
Many of you, as well as your employees, have asked “what does health care reform mean to me?”. The purpose of this update is to provide you with information in plain English. We have included a preliminary Implementation Timeline as well as a draft of an Employee Memo that you can customize for communications with your employees. The timeline included with the employee memo is much less detailed than the one we have attached for your use. Depending on your employee population, you may like to share the more detailed timeline with your employees. We hope that you and your employees find this information helpful.
Important Concepts
> Grandfathering
Group health plans that exist as of March 23, 2010 are “grandfathered” under the Act. Grandfathered plans that are deemed to offer “minimum essential benefits”, have delayed effective date rules for certain reforms and are exempt from some other changes. Some reforms will apply to grandfathered plans upon their first renewal after September 23, 2010, however.
A grandfathered plan can enroll new employees and dependents. It is unclear, however, what other changes may be made to the plan without disqualifying its grandfathered status.
> Collectively-Bargained Plans
Plans that are maintained under a collective bargaining agreement as of March 23, 2010 may postpone changes mandated by the act until the date the collective bargaining agreement expires with the exception of the reforms that are also applied upon the first renewal after September 23, 2010 to grandfathered groups. Our current understanding is that these reforms will also apply to collectively bargained groups.
> Self-Insured vs. Fully Insured Plans
All of the information shared in this update applies to both fully –insured and self-funded plans.
As more information and guidance becomes available, we will continue to provide updates. Should you have any questions, or need additional information on any provision of the law, please contact any member of your account management team at (404) 846-8883. We look forward to working with you through the upcoming challenges!
ATTACHMENTS:
4/19/10 Alert - Health Care Reform Update - implementation timeline
4/19/10 Alert - Health Care Reform for Employees