The FAQs clarify that if a plan adopts an amendment that causes it to lose its grandfathered status, the effective date of the loss of status will be the effective date of the amendment. The date the amendment was signed is irrelevant.

This recent guidance reflects the agencies’ continued commitment to provide guidance regarding the implementation of PPACA. As we approach the effective dates for other PPACA provisions, we expect that the agencies will publish additional guidance. Stay tuned.

All the DOL FAQs on the new health care law can be found by clicking on the FAQs tab at the DOL Employee Benefit Security Administration website at You can go directly to this most recent release at: