Although several of PPACA's plan design provisions took effect in 2011, employers that currently provide group health plan coverage must now prepare for phase two of implementation of the PPACA. Between now and the end of 2014, those employers need to make several plan design changes and comply with significant new administrative, employee communication and reporting requirements. Employers must act quickly and decisively because the compliance steps they take in the next 18 months will position them for the employer mandate in 2014.
The following chart highlights some of the major compliance requirements facing employer-sponsored group health plans between now and the end of 2014.
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In addition to the items highlighted above, there are other requirements for which the effective dates are not certain. These include: a quality of care reporting requirement, an automatic enrollment requirement for employers with more than 200 full-time employees, and a new nondiscrimination rule which will affect how insured health plans will have to be structured and maintained. Employers must remain vigilant in their review of forthcoming guidance on these matters to ensure timely compliance