Throughout 2010, the U.S. Departments of Health and Human Services, Labor and the Treasury (collectively, the Departments) issued interim final regulations (IFR) implementing ACA market reforms applicable to grandfathered health plan coverage (ACA Section 1251), prohibition of preexisting condition exclusions (Public Health Service Act (PHSA) Section 2704), prohibition on lifetime or annual limits (PHSA Section 2711), extension of dependent coverage (PHSA Section 2712), internal claims and appeals and external review process (PHSA Section 2719), and various other patient protections (PHSA Section 2719A) (collectively, the 2010 Interim Final Regulations). On November 18, 2015, the Departments issued final regulations (the Final Regulations) on all topics in the 2010 Interim Final Regulations.

..Grandfathered Health Plan Interim Final Regulations

..Preexisting Condition Exclusions, Lifetime and Annual Limits Interim, Rescissions, and Patient Protections Interim Final Regulations

..Claims and Appeals Interim Final Regulations

The Final Regulations generally adopt the rules of the 2010 Interim Final Regulations (IFR) without substantial change, and incorporate clarifications issued to date in various forms of sub-regulatory guidance. The following includes a high level overview of the finalized rules and new clarifications under the Final Regulations.