Further Guidance on Healthcare Reform Provisions
The departments of Treasury, Labor (DOL) and Health and Human Services (HHS) issued interim final rules for group health plans and health insurance coverage under provisions of the Patient Protection and Affordable Care Act (PPACA). The interim final rules address the issues of preexisting condition exclusions, lifetime and annual limits, rescissions and patient protections under PPACA. The 196-page document can be located at: http://www.federalregister.gov/OFRUpload/OFRData/2010-15278_PI.pdf.
We are currently reviewing the information and will provide members with a summary as soon as possible.
One issue that has become clearer is that health plans under a Collective Bargaining Agreement (CBA) will not be afforded special rules as was first expected. The common school of thought was that the DOL would be consistent with past federal mandates in delaying provisions of PPACA until the expiration of the existing CBA.
However, when the Treasury, DOL & HHS issued interim final rules on June 14th regarding “grandfathering”, they provided virtually no relief in the form of exceptions for CBAs. CBAs are treated basically the same as all other group health plans under the general Grandfathered Plan Rules.
As we research more about the impact of these recent releases, we will notify our members. Look for further summary information in the next two to three weeks.