As your benefit plan professionals, MedCon feels it is important to keep you informed on the latest changes and/or additions to the complicated Patient Protection and Affordable Care Act.
There are several compliance regulations that are scheduled to be in effect soon. You may not have to comply with some of these regulations depending upon your plan status with regard to the “Grandfather” clause. Even if your plan qualifies under the clause, the following provisions are required for all benefit plans renewing on or after September 23, 2010.
- Dependents covered to age 26
- No pre-existing conditions for those under the age of 19
- No lifetime annual coverage limits for “essential health benefits”
The following is a general compliance checklist:
- Insure an open enrollment process is available to accommodate the 30-day “special enrollment period” for adult dependent children. (This special enrollment is for those adult children who previously became ineligible due to age limits.)
- Identify any individuals who have met the current “lifetime” or “annual” benefit limit and are still eligible to participate in the plan. A special 30-day enrollment period must be provided for anyone in this category as well.
- Correct any current plan wording that is contrary to the pre-existing condition ban based on those under age 19.
- Evaluate and correct FSA plan designs to coincide with the new exclusion for reimbursement of over the counter drugs purchased on or after January 1, 2011.
- Prepare the new W-2 reporting requirements effective for the 2012 plan year. Total cost of medical benefits will be reported on the 2013 W-2.
- Determine your plan’s “Grandfather” status. If yes, then have proper documentation. If no, make sure your plan covers the required “preventive care services” with no cost sharing by the participant.
- Make sure your plan is in compliance with the emergency service provision. Your plan may not require prior authorization for hospital ER services even if they are out of network. Both in and out of network benefits must be the same insofar as copays and coinsurance is concerned.
- If you employ more than 200 employees you must be prepared to auto-enroll all full time employees as soon as they are eligible for coverage. Although the date of implementation has not yet has not been set, this is part of the new regulations.
If you have questions or would like more information on healthcare reform, please contact Sharon McReynolds at 214.739.5215 ext. 102.
*This article is intended to provide general guidance and should not be considered legal advice.