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PPACA Healthcare Reform Timeline Courtesy of:. 6500 City West Parkway Suite 100 Eden Prairie, MN 55344 (952) 944-2929 www.horizonagency.com. Minimum Loss Ratios Page 4 Coverage Appeals Process Page 5 Expansion of Non Discrimination Rules Page 5 Annual Benefit Limits Page 6
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PPACA Healthcare Reform Timeline Courtesy of: 6500 City West Parkway Suite 100 Eden Prairie, MN 55344 (952) 944-2929 www.horizonagency.com
Minimum Loss Ratios Page 4 Coverage Appeals Process Page 5 Expansion of Non Discrimination Rules Page 5 Annual Benefit Limits Page 6 Lifetime Benefit Limits Page 6 Increased Dependent Coverage Page 6 Coverage of Emergency Services Page 6 Coverage of Preventive Care Page 6 Designating a Primary Care Physician Page 7 Rebates for Medicare Part D “Donut Hole” Page 7 Reporting on W-2s Page 8 Long Term Care Program Page 8 Health FSA, HRA, HSA Reimbursements Page 8 HSA and Archer MSA Distribution Increases Page 8 Federal Study on Self-Insured Plans Page 8 Tax to Fund Comparative Effectiveness Research Page 9 New Plan Disclosure Requirement Page 9 Material Modification of Plan Provision Page 9 FSA Limit Page 9 Medicare Payroll Tax Increase Page 10 Medical Expense Deduction Page 10 New Employer Discloser Obligation Regarding Exchanges Page 10 New Reporting Obligation Regarding Employers Furnishing Quality and Affordable Coverage Page 11 Table of Contents
New Obligation Regarding Employee’s “Minimum Essential Coverage” Page 11 Employee Waiting Period for Coverage Page 11 Free Choice Vouchers Page 12 Employer Penalty for Offering Coverage that’s not “Qualifying” and “Affordable” Page 13 Determination and Potential Application of Employer Penalty for Categories of Employees Page 14 Pre-Existing Conditions Page 15 Wellness Program Page 15 Coverage for Clinical Trials Page 15 Annual Benefit Limits Page 15 Modified Community Rating Requirements Page 16 State Based Exchanges Page 17-18 Excise Tax on High Value Health Plans “Cadillac Plans” Page 19 Auto Enrollment by Employers Page 19 Individual Mandate Page 20 Helping Employees Prepare for Health Care Reform Legislation (Individual Refusal to Purchase Coverage) Page 21 Health Care Reform – Estimated Financial Impact For Employers Page 22 Health Care Reform “Grandfathered” Provision Page 23 - 26 Preventive Care Services Page 27 - 29 Table of Contents
Health Care Reform Effective Dates 4
Health Care Reform Effective Dates 5
Health Care Reform Effective Dates 6
Health Care Reform Effective Dates 7
Health Care Reform Effective Dates 8
Health Care Reform Effective Dates 9
Health Care Reform Effective Dates 10
Health Care Reform Effective Dates 11
Health Care Reform Effective Dates 12
Health Care Reform Effective Dates 13
Determination and Potential Application of Employer Penalty for Categories of Employees 14
Health Care Reform Effective Dates 15
Health Care Reform Effective Dates 16
Health Care Reform Effective Dates 17
Health Care Reform Effective Dates 18
Health Care Reform Effective Dates 19
Helping Employees Prepare for Health Care Reform Legislation (Individual Refusal to Purchase Coverage) 20
Helping Employees Prepare for Health Care Reform Legislation (Individual Refusal to Purchase Coverage) Penalty Table 21
Health Care Reform – Estimated Financial Impact for Employers *These are the impacts for typical cases. The impact for any specific case may vary from these amounts. **Not required of Grandfathered Plans. 22
General Requirements Regulations also condition grandfathered status on the sponsor taking the following affirmative steps: Including “in any plan materials provided to a participant or beneficiary that describes the benefits provided under the plan” (such as a summary plan description) a statement that the plan believes it is a grandfathered health plan within the meaning of Section 1251 of the Act. This statement must also provide contact information for questions and complaints. The regulations include model language that may be used to satisfy this disclosure requirement. Maintaining records that document the terms of the plan as in effect on March 23, 2010, along with any other documents necessary to verify, explain, or clarify, the plan’s status as grandfathered health plan. Those records must then be made available for examination upon request by a participant, beneficiary, or government agency. In addition to being in effect on March 23, 2010, a grandfathered plan must avoid taking any action that would undermine its grandfathered status. The types of actions that would cause a plan to lose its grandfathered status are described in the next section. Healthcare Reform “Grandfathered” Provision 24
Actions that would result in losing “Grandfathered” status: Change in insurance carrier, policy, certificate or contract. Elimination of all benefits to diagnose or treat a particular condition. Any increase in coinsurance. An increase in deductibles or copayments subject to the applicable cost-adjustment test established by the federal government. Compared with copayments in effect on March 23, 2010, grandfathered plans will be able to increase those copayments by no more than the greater of $5 (adjusted annually for medical inflation) or a percentage equal to the medical inflation plus 15 percentage points. Compared with the deductible required as of March 23, 2010, grandfathered plans can only increase these deductible by a percentage equal to medical inflation plus 15 percentage points. Change in funding status from self-funded to fully insured. A decrease in employer contribution of more than 5%. Healthcare Reform “Grandfathered” Provision 25
Actions that would NOT result in losing “Grandfathered” status: Changes to premium – as long as there isn’t more than a 5% reduction in the percentage of the employer’s contribution. Changes to increase benefits, or voluntarily comply with provisions of federal and state law as long as changes comply with the applicable grandfathering restrictions. Changes to a provider network. Changes to a prescription drug formulary unless the changes act to eliminate a benefit. Changes to accommodate mergers and acquisitions. Changes to a plan’s third party administrators as long as the benefits continue to satisfy grandfathering. Changing funding status from fully insured to self-insured as long as the benefits continue to satisfy grandfathering. The regulations provide that the grandfathering rules apply separately to each "benefit package" made available under a health plan. Thus, a plan offering both an HMO and a PPO option might choose to modify the PPO's deductible or copayment in a way that would cause the PPO to lose its grandfathered status, without thereby forfeiting the HMO's grandfathered status. Healthcare Reform “Grandfathered” Provision 26
The following is a checklist of procedures and services that are classified as “preventive services” under PPACA. These services are to be covered without copayment, coinsurance, and/or deductible when provided by an in-network provider effective September 23, 2010 or first plan renewal there after. Preventive Care Services 27