![]() ![]() As a result, if a group health plan modifies the tiers of coverage it had on Ma(for example, from self-only and family to a multi-tiered structure of self-only, self-plus-one, self-plus-two, and self-plus-three-or-more), the employer contribution for any new tier would be tested by comparison to the contribution rate for the corresponding tier on March 23, 2010. The interim final grandfather regulations provide that the standards of paragraph (g)(1)(v) for employer contributions (listed above as item (5) in Q&A-1) apply on a tier-by-tier basis. How do the Departments’ interim final grandfather rules regarding changes in employer contributions apply where an employer restructures its tiers of coverage?Ī3. Accordingly, if any benefit package ceases grandfather status, it does not affect the grandfather status of the other benefit packages In this situation, it is permissible to treat the PPO, POS arrangement, and HMO as separate benefit packages. The grandfather analysis applies on a benefit-package-by-benefit-package basis. If the HMO relinquishes grandfather status, does that mean that the PPO and POS arrangement must also relinquish grandfather status?Ī2. My plan offers three benefit package options – a PPO, a POS arrangement, and an HMO. (As noted, the Departments are separately considering under what circumstances otherwise grandfathered plans may change issuers without relinquishing their status as grandfathered health plans.) ![]() Briefly stated, these six changes are:ġ.Elimination of all or substantially all benefits to diagnose or treat a particular condition.Ģ.Increase in a percentage cost-sharing requirement (e.g., raising an individual’s coinsurance requirement from 20% to 25%).ģ.Increase in a deductible or out-of-pocket maximum by an amount that exceeds medical inflation plus 15 percentage points.Ĥ.Increase in a copayment by an amount that exceeds medical inflation plus 15 percentage points (or, if greater, $5 plus medical inflation).ĥ.Decrease in an employer’s contribution rate towards the cost of coverage by more than 5 percentage points.Ħ.Imposition of annual limits on the dollar value of all benefits below specified amountsįor a plan that is continuing the same policy, these six changes are the only changes that would cause a cessation of grandfather status under the interim final regulations. Paragraph (g)(1) of the Departments’ interim final grandfather regulations provides that any of six changes (measured from March 23, 2010) are considered to change a health plan so significantly that they will cause a group health plan or health insurance coverage to relinquish grandfather status. If we avoid making any of the six specific changes described in paragraph (g)(1) of the interim final regulations relating to grandfathered health plans, are there other changes to our existing plan/policy that we need to be concerned could cause it to relinquish grandfathered status? Ī1. We and the issuer of the policy under the plan are considering whether we could make various changes to the plan without losing grandfathered status. Our company sponsors a group health plan for our employees that has been in effect since March 23, 2010. Table of ContentsĪCA Effective Date for Individual Health Insurance Policies Grandfathered Health Plans We hope these publications will be helpful by providing additional clarity and assistance. ![]() The Departments anticipate issuing further responses to questions and other guidance under the Affordable Care Act in the future. The ongoing guidance the Departments are providing reflects our approach to implementation, which emphasizes assisting (rather than imposing penalties on) plans, issuers and others that are working diligently and in good faith to understand and come into compliance with the Affordable Care Act, as well as our commitment to work with families and individuals to make it as easy as possible for them to obtain the protections and benefits of the new law. These FAQs answer questions from stakeholders with a view to helping people understand the new law and benefit from it, as intended. They have been prepared jointly by the Departments of Health and Human Services, Labor and the Treasury. Set out below are a number of Frequently Asked Questions (FAQs) regarding implementation of the market reform provisions of the Affordable Care Act. ![]()
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