First Wave of Health Care Reform Requirements Take Effect For Plan Years Beginning on or After September 23, 2010

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When Must Your Plan Comply? Group health plans and health insurance issuers are required to comply with a host of PPACA's requirements by the first "plan year" beginning on or after September 23, 2010. For plans that operate on a calendar plan year basis, this means a compliance deadline of January 1, 2011. Employers who are uncertain of the start date of their next plan year should find it in the "general information" section at the back of their plan booklet or consult their employee benefits professional.

When Must Your Plan Comply? Group health plans and health insurance issuers are required to comply with a host of PPACA's requirements by the first "plan year" beginning on or after September 23, 2010. For plans that operate on a calendar plan year basis, this means a compliance deadline of January 1, 2011. Employers who are uncertain of the start date of their next plan year should find it in the "general information" section at the back of their plan booklet or consult their employee benefits professional.

Requirements Affecting All Plans. There are two types of requirements that will take effect for the upcoming plan year – the first group applies to all group health plans and the second applies only to plans that are considered "non-grandfathered" under recently issued interim federal regulations. The requirements that apply to all plans are as follows:

-Extension of dependent coverage to children up to age 26;

-Elimination of lifetime dollar limits on essential benefits and gradual elimination of annual limits;

-Elimination of pre-existing condition exclusions for children under age 19;

-Elimination of retroactive rescissions of coverage (except for fraud, misrepresentation and non-payment);

-Elimination of reimbursement for most over-the-counter medications under HRAs, HSAs and FSAs and an increased excise tax for non-qualified distributions under these plans (effective January 1, 2011).

Please see full article below for more information.

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Published In: Administrative Agency Updates, Health Updates, Insurance Updates, Labor & Employment Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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