Agencies Issue PPACA Implementation Guidance
On March 23, 2010, President Obama signed into law the Patient Protection and Affordable Care Act (PPACA). Six months later, the PPACA's "first round" of coverage mandates are set to go into effect. Group health plans must comply with the following coverage mandates beginning with their next plan year (Jan. 1, 2011, for calendar year plans):
- Extension of dependent coverage to age 26;
- Elimination of pre-existing condition exclusions for enrollees under age 19;
- Prohibition on lifetime and annual dollar limits;
- Prohibition on rescissions;
- Provision of first dollar coverage for preventive health services (non-grandfathered plans only);
- Internal claims and appeals procedures and external review process (non-grandfathered plans only);
- Mandated patient protections (non-grandfathered plans only);
- Non-discrimination rules extended to insured plans (non-grandfathered plans only); and
- No discrimination based on health status (non-grandfathered plans only).
Since the enactment of the PPACA, the Departments of Labor (DOL), Health and Human Services, and the Treasury have jointly published several phases of interim final regulations, issued sub-regulatory guidance, and invited comments concerning many of the changes that will impact employers and retirement systems that sponsor group health plans.
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