May 2010 Regulation Update

As more pieces of the healthcare reform puzzle come together through the release of the regulations, it is important that you look at both the short term and long term compliance requirements. At Valley Forge Benefits Consulting, we can help develop a strategy to deal with all of the various components of reform.

To start planning for the year ahead, we have laid out the chart below of immediate action steps which employers may need to take. This should be used as a starting point in your organization’s journey of healthcare reform compliance.

The first critical action is to determine whether your plan qualifies as a grandfathered plan. The definition of a grandfathered plan is any group health plan or individual coverage that was in effect on March 23, 2010, the date of the new law’s enactment. Newly hired employees may enroll in the health after the effective date without changing the plan’s grandfathered status. Likewise, an individual who was covered by a grandfathered health plan may add his or dependents to the plan after March 23, 2010 without negating the plan’s grandfathered status.

Since we think it is essential for busy employers to understand the short and long term impact, we have started this chart, with just 2011 changes. This chart is not fully representative of all aspects of 2011 changes, but highlights the critical action steps that employers will need to take, particularly with regard to plan amendments. There will be future publications detailing changes scheduled for later years, as well as components like under 65 retiree and Medicare Part D. For any plans that are deemed to be grandfathered, pay particular attention to the column indicating whether the listed requirement applies to your plan. Also, we have noted whether the official regulations have been released. As more regulatory guidance becomes available, we will fill in the boxes and add additional clarification.

We look forward to supporting our clients in the months and years to come on the road to healthcare reform compliance.