In the last two months, the Department of Labor, the Internal Revenue Service and the Department of Health and Human Services published three additional sets of interim final regulations to address compliance requirements in the first significant round of changes to impact group health plans under the Patient Protection and Affordable Care Act (PPACA). The regulations add details to new requirements or prohibitions relating to pre-existing condition limitations, lifetime and annual limits, and coverage rescissions, as well as a proposed set of patient protections, known informally as a "patient bill of rights." They also address new preventive care coverage requirements and new requirements for claims and appeals procedures. The preventive care and claims and appeals requirements apply only to non-grandfathered plans. The other new rules will apply to all employer group health plans, whether or not grandfathered and whether insured or self-insured. These changes are effective for group health plans beginning the first plan year that begins on or after September 23, 2010 (which means they are effective January 1, 2011, for calendar year plans).
We have updated our Health Care Reform Q&A in light of the new interim final regulations. (Questions and answers affected by this guidance are marked "updated" or "new" in our Q&A.)
The Updated Q&A page can be accessed at: www.bakerdaniels.com/employer-hcr-qa.