What you need to know:
The US Supreme Court has upheld the individual mandate in the Patient Protection and Affordable Care Act, and the employer and group health plan requirements were left unchanged. The Act contains group health plan requirements and new administrative responsibilities for employers.
What you need to do:
Employers should review their group health plan documents to ensure that their plans are in compliance with the applicable provisions of the Act, and they will also need to address the new administrative requirements contained in the Act.
Key Provisions Impacting Employers
Now that the US Supreme Court has upheld the individual mandate in the Patient Protection and Affordable Care Act, and the Act’s employer and group health plan requirements were left unchanged, what does this mean for employers?
Employers will need to review their group health plan documents to ensure that their plans are in compliance with the applicable provisions of the Act. In addition, there are new administrative tasks for employers with respect to their group health plans. The table below highlights the key provisions impacting employers, effective for plan years beginning on or after July 1, 2012 and prior to 2014.
Click here to view table
Further Requirements Effective in 2014
Additionally, a host of new health plan requirements become effective in 2014. Employers should anticipate further regulatory guidance on the following Patient Protection and Affordable Care Act developments:
- Waiting periods for plans may not exceed 90 days
- No annual dollar limits may be imposed on essential health benefits (the elimination of annual dollar limits has been phased in since 2010)
- No pre-existing condition limits permitted
- New cost-sharing and deductible limits (for nongrandfathered plans only)
- Wellness incentives increased (for nongrandfathered plans only)
- Coverage of routine patient costs for individuals participating in approved clinical trials (for nongrandfathered plans only)
- Automatic enrollment requirements
- Shared responsibility (pay or play) mandate for employers
- Individual mandate
- Availability of state-based health insurance exchanges
- Premium tax credits for certain individuals
- New rating restrictions and guaranteed availability and renewability requirements for insurers
- Excise tax on high cost coverage (“Cadillac tax”) (not until 2018)