Grandfathered Plan Status
Is your plan a grandfathered one? If it existed when health care reform went into effect on 3/23/2010, it may be exempt from some of the PPACA requirements. Note: this status will affect compliance obligations from year to year.
Certain plan changes can remove your plan from grandfathered status. Check with us if you're not sure of its status.
If you do move to a non-grandfathered plan, you'll want to be sure that participant rights and benefits like first dollar coverage of preventive care, enhanced claim and appeal process and non-discrimination rules (for insured plans) are in place.
Note: non-grandfathered plans must cover specific women's preventive health services effective for plan years starting on or after August 1, 2012.
Small Business Tax Credit
Do you have fewer than 25 employers and pay average annual wages of less than $50,000? You may qualify for the small business tax credit via PPACA. Check with your tax planning professional so you don't miss out!
Self-Funded Plans Comparative Effectiveness Research Fee
Effective with the plan's first renewal after October 1, 2012, self-funded plans pay $1 per covered life fee for comparative effectiveness research. The following year, fees go to $2 per covered life, and then are indexed for inflation in years following.
Medical Loss Ratio Rebates
MLR provisions require health insurers to spend 80 to 85 percent of premium dollars on medical care and health care quality improvement, rather than administrative costs, beginning in 2011. Insurers that do not meet these requirements must provide rebates to consumers beginning in 2012. Rebate distributions would be due in August 2012.
Source: EmSpring Legislative Briefs: 2012 Compliance Checklist, HHS Issues Medical Loss Ratio Rules. Note: all Legislative Briefs are also available to clients via MyWave. Contact us for more info.
