Federal agencies and the White House have started to provide guidance on a few of the many issues and opportunities created by the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act (collectively referred to as "PPACA" in our Health Care Reform Q&A). The new guidance issued to date includes a White House release on PPACA's requirements for extended coverage of adult dependent children and an IRS notice on the tax treatment of that extended coverage, and Department of Health and Human Services regulations on the new temporary reinsurance program for early retiree health plans.
In light of this new guidance, we have updated our Health Care Reform Q&A, which provides our thoughts on a variety of questions raised by employers and their service providers about how PPACA impacts employer-sponsored health plans, based on the statutory language, legislative history, and the guidance available to date. Our update also includes answers to additional questions posed to us by employers and service providers since the initial launch of our Q&A. We will continue to update this list of questions and answers regularly on our Web site, as we receive more questions from our clients and guidance from government agencies, so please continue to check back often.
As we were going to press with this update, the DOL, IRS, and HHS issued joint guidance (in the form of interim final regulations) on the new requirement to extend dependent child coverage to an employee's child up to age 26. We have made a few modifications to the Q&A to take into account this latest guidance, but we expect to have some additional updates later this week once we have had more time to digest the new guidance and entertain additional questions arising from it.
The Q&A page can be accessed at: www.bakerdaniels.com/employer-hcr-qa.