BMI Newsletter 11/23/10
Dear BMI Client, November 23, 2010
It seems like some of the dust is settling as more Health Reform details have been written. Maybe it’s because we study it every day, but we feel as if we have a pretty good handle on the compliance requirements. Nearly all BMI clients will retain their Grandfathered Plan status and have to make very few changes in benefits or eligibility. The required changes for most Plans on their first renewal after September 23, 2010 are:
1) No pre-existing exclusion for children or spouses (persons under 19).
2) Eligibility for children, stepchildren and foster children up to their 26th birthday as long as they are not eligible for coverage through their own or spouse’s employer.
3) No dollar annual maximums on Essential Benefits (list is yet to be published).
To maintain Grandfathered Plan status, you must avoid the six prohibited items:
1) Elimination of substantially all of a benefit to diagnose or treat a particular condition.
2) Any increase in the percentage of contribution by the member after 3/23/10.
3) Increase in deductible of more that 15% plus medical inflation.
4) Increase in copayments by 15% plus medical inflation or $5.00.
5) Decrease in employer contributions for any tier of coverage or class of individuals by more than 5% below the period including 3/23/10.
6) Certain changes in annual limits.
Plans will have to give 60 days notice of benefit changes but that requirement does not go into effect until the Essential Benefits list and 4-Page Summary of Benefits format are published.
For Grandfathered Plans, the balance of PPACA changes will be required on the first Plan anniversary on or after January 1, 2014. Dental and Vision benefits are considered an integral part of the plan only if employees or dependents can not elect those benefits separately. If they are not an integral part of the plan, market reform provisions do not apply to that coverage.
BMI is providing all PPACA guidance at no expense to our clients. We are also offering additional governmental reporting compliance for Medicare and Medicaid Section 111. We will provide more details on that next week but have a Happy Thanksgiving!This entry was posted in Uncategorized. Bookmark the permalink.
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