Universal Benefit Plans Blog

The first wave of the PPACA’s (i.e. health reform) employer mandates take effect for all plan years beginning on or after September 23^rd and employers must thoroughly communicate all required changes at enrollment meetings. That's why we've put together a very handy “to do” list of employer steps to compliance.

October-December renewals especially take note, we’ve put together the list’s key items as they pertain to specific health reform provisions.

Employer requirements for plans providing adult dependent coverage:

• Describe adult child eligibility (including restrictions if your current plan will be grandfathered over)
• Offer a special enrollment opportunity of at least 30 days to benefits-eligible employees’ dependents—including those who have dropped the plan or whose parents have waived coverage—and provide prominent written notice of it
• Make coverage effective as of the first day of the plan year

Employer requirements for plans eliminating lifetime dollar limits:

• Expressly state in writing that your plan no longer has lifetime dollar limits and that individuals affected by prior limits are again eligible for coverage.
• Offer a special enrollment opportunity of at least 30 days for these individuals and provide prominent written notice of it.
• Make coverage effective as of the first day of the plan year.

Plans with pre-existing condition exclusions:

• Delete all references to pre-existing conditions for children under age 19

Plans offering tax advantaged accounts (i.e. FSA, HRA, HSA, etc.):

• Explain new limits on reimbursements for over-the-counter drugs effective 1/1/2011

Non-grandfathered plans:

• Delete all references to cost-sharing on preventative services, pre-authorization requirements for emergency services and referrals for OB/GYN services.
• If the plan requires designation of a primary care practitioner (PCP), ensure that plan participants have an adequate range of doctor choices.

CLASS Act LTC Program:

• Describe program and costs to employees.
• Provide automatic enrollment and facilitate payroll deductions. Also, inform employees of their choice to opt out of the program and that they must do so if they don’t want to be automatically enrolled.

Plan Cancellation Conditions:

• Update plan communications to reflect new PPACA cancellation standards.
• Even in cases where rescission is permitted, plans must give participants written notice at least 30 days before their coverage is terminated.

As you can see from all of the above, employers will be very busy combing through plan communications, conducting dependent audits and preparing employee communications for the CLASS Act (which quite frankly the government hasn’t done the best job communicating to us). That being said, employers should make absolute certain they have a written timeline of all upcoming changes to health insurance. That way, they know exactly what needs to be done in the immediate future, at enrollment time and in years to come.

One final parting note, Universal Benefit Plans will be holding a webinar this fall on the CLASS Act and the employer responsibilities that come along with it. Stay tuned for more info in the months that follow.