On March 1, 2013, the Department of Labor’s Employee Benefits Security Administration (DOL) published a new self-compliance tool for the Affordable Care Act (“ACA”) on its website. This self-compliance tool is intended to provide an informal explanation of the ACA regulations and interpretations that apply to group health plans such as employer-sponsored plans. The selfcompliance tool, however, only focuses on the provisions noted below, which are already in effect.
- Grandfathered Status
- Dependent Coverage of Children to Age 26
- Prohibitions on Lifetime Limits and Restrictions on Annual Limits
- Preexisting Condition Exclusion for Individuals Under 19
- Summary of Benefits and Coverage (SBC) and Uniform Glossary
- Patient Protection Provisions
- Coverage of Preventive Services
- Internal Claims and Appeals and External Review
While this tool does not currently include any guidance on the employer shared responsibility provisions, it does provide employers with a checklist format to help determine whether their group health plans are “grandfathered” for purposes of ACA and whether their group health plans comply with these other provisions of ACA that are already in effect.