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Blog by: Jeanne Hines, SPHR

Several new provisions and laws regarding health care reform have been finalized in the last month or so.  Today’s blog will address a couple of health care issues that made their way to the forefront in March.

Proposed Rules Regarding 90-Day Limitation on Waiting Periods

The proposed rules implement a 90-day waiting period limitation.  A waiting period is defined as a time period that must pass before coverage for an employee or dependent who is otherwise eligible to enroll under the terms of the group health plan can become effective.  This section will apply to grandfathered and non-grandfathered group health plans for plan years beginning on or after January 1, 2014.

Employers who currently have coverage that begins on the first of the month following 90 days of employment will need to change their eligibility to comply with the new rule.  Employee coverage must begin no later than the 91st day of employment unless the employee fails to enroll in a timely manner.

Benefit and Payment Parameters Final Rule

The HHS Notice of Benefit and Payment Parameters final rule was released on March 1, 2013.  To stabilize premiums as new consumer protection begin in the individual and small group market in 2014, the Affordable Care Act creates three programs– risk adjustment, reinsurance, and risk corridors. These programs will work with the premium tax credits, cost-sharing reductions, medical loss ratio program and new market reforms, including the guaranteed availability (also known as guaranteed issue) protections and prohibition of the use of factors such as health status, medical history, gender, and industry of employment to set premium rates, to help ensure every American has quality, affordable health insurance.  You can read more about it here:  HHS Fact Sheet

The Final Rule also addresses the Small Business Health Options Program (SHOP) at the federal level.  This won’t have a significant impact on Minnesota, as our state is creating its own SHOP.  Iowa and Wisconsin may see a different impact due to the Federal program only offering one option for SHOP participants during 2014.

New FAQ Addresses Compliance by Expats

If your health plan covers employees and their dependents who reside outside of the United States for at least six months of the plan year, this new release will be of interest to you.  Due to the challenges in complying with several of the provisions of the Affordable Care Act, expat plans will have somewhat of a reprieve of compliance until December 31, 2015.  Plans are not exempt from any of the pre-ACA requirements such as ERISA, Title XXVII of the PHS Act, and the Internal Revenue Code.  For more information see the FAQ:  Ex Pat FAQ

Minnesota Exchange Becomes Law

The Minnesota legislature passed a new law establishing health insurance exchanges in the state at the end of March.  Minnesota’s exchanges will be governed by a board of directors and will begin offering coverage on January 1, 2014.  Enrollment for individual and small business coverage will be open from October 1, 2013 through March 31, 2014.

We are currently awaiting information from the state and from carriers regarding the details of plans being offered.  We will provide additional detail when the information is available.  In the meantime, please let us know what questions you may have.

Upcoming Webinar on April 17th

Did you miss the webinar regarding the Employer Shared Responsibility (also known as Play or Pay) the first time around?  Did you view the webinar and like it so much that you want to see it again?  You're in luck!  Because of the overwhelming response, we've selected a second LIVE webinar air date!  See our website for more details.  Space is limited.

 

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