It’s time to take a breather from the voluminous sets of regulations related to the Affordable Care Act (ACA) health care reform law. Here’s news that’s easier to digest.
Another postponement. Included in the Center for Medicare and Medicaid Services’ recent announcement, that states may allow individuals who have policies that aren’t ACA-compliant to renew those policies through the 2016 policy year, was that this additional two-year postponement also applies to employers in the small group market.
Under these revised guidelines, employers in the small group market, and employers that currently purchase group plans in the large group market but, that as of Jan. 1, 2016, will be slotted into the small group market (generally employers with up to 100 employees) may, if their state insurance departments and insurers allow, continue to purchase or renew non-ACA-compliant group plans through Oct. 1, 2016.
NOT A BLANKET REPRIEVE: Regardless of when purchased, all group plans must not impose any pre-existing exclusion period on adults. Likewise, plans can’t discriminate against participants based on their health status.
Deductibles for small employer plans. The ACA originally limited deductibles for small employer plans to $2,000 for employees with self-only coverage and $4,000 for employees with family coverage. The Protecting Access to Medicare Act (P.L. 113-93) eliminates these limits, effective retroactive to March 23, 2010, the date the ACA was signed.
Reinsurance rate set for 2015. Through 2016, insured and self-insured group plans that provide major medical coverage, including COBRA plans, retiree plans and grandfathered plans must pay annual reinsurance fees. The fees are intended to spread risk, stabilize premiums and ensure stability in the group market. For ERISA-covered plans, the fees are permissible plan expenses. All plans may deduct the fees as ordinary and necessary business expenses.
For 2015, the Department of Health and Human Services has announced that the annual fee is $44 per covered life, or $3.67 a month. (79 F.R. 13743, 3-11-14)
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