Proceeding with PPACA's Health Reforms
With the U.S. Supreme Court upholding the individual mandate and other provisions of the Patient Protection and Affordable Care Act (PPACA) affecting employment-based healthcare coverage, group health plan sponsors should turn their focus to implementing and complying with the law’s various reforms. A number of provisions become effective in the near term, while others engage several years from now. PPACA’s effects on employer-sponsored group health plans will differ in part on whether a plan is “grandfathered” (i.e., existing in relatively unmodified form since the law’s March 23, 2010 enactment), insured, or considered large, but many of the law’s requirements apply regardless.
This Client Action Bulletin summarizes PPACA’s upcoming provisions for which employer-sponsored group health plans should prepare. Because the federal agencies with oversight – the Departments of Treasury, Labor, and/or Health and Human Services (Treasury, DOL, DHHS) – have not published all necessary guidance to date, plan sponsors may face additional pressures and uncertainties about their responsibilities and with compliance issues.
Commercial risk adjustment and transfer payments: Are you ready?