Posts Tagged: Affordable Care Act

Annual Limit Waiver Guidance Updated

in Affordable Care Act

In previous posts I discussed the annual limit waiver process for mini-med plans as well as the upcoming MLR rules regarding mini-med plans.  Today, OCIIO amended the annual limit waiver application process for mini-med plans, including adding a participant notice requirement.  This notice is yet to be posted to the website, but it is required to be sent to participants in a plan that has obtained an annual limit waiver.  OCIIO also announced its intention to provide a special methodology for mini-med plans to better satisfy the upcoming MLR rules.   The special methodology is expected to be available for at least the first year the MLR rules are… Continue Reading


in Affordable Care Act

This morning the DOL released three more FAQs dealing with grandfathered plans.  These additional FAQs are referred to as Part IV on the website and linked here: I certainly hope at one point DOL combines all these FAQs into a single guidance document or includes the guidance in the regulations when the interim final regulations are finalized.

ERRP Reporting Now Live

in Affordable Care Act

I have spent the last few days speaking at the JCEB National Health and Welfare Institute here in DC and have unfortunately not been keeping up with recent events.  One such recent event is that there is much happening with the ERRP right now.  Currently, the cost reporting and reimbursement request features are now live for plan sponsors with approved applications.  If you are waiting for your application to be approved, you should review the requirements so that you are ready to submit once the approval comes through.  Click here for additional information:

NAIC Finalizes MLR Rules

in Affordable Care Act

Today, the NAIC finalized its controversial MLR regulations, and have sent them to HHS.  In turn, HHS will turn the MLR rules into regulations under the Affordable Care Act.  In the process, HHS can certainly revise or tweak the MLR rules, including, for example, to make it easier for mini-med plans to pass the requirements.  A few weeks ago we posted a news release by HHS stating that they understood the challenges that mini-med plans face and they intended to revise the MLR rules as appropriate for mini-meds.  The link below discusses the passage of the final rules.

Retiree Health Plans – Beware of What you Wish for

in Affordable Care Act, Retiree Benefits

Our September 28th blog entry discussed retiree-only plans and that to solidify their exemption from the ACA employers should put those benefits into separate ERISA plans.  For months, some attorneys have been hammering away at the Departments regarding this issue (but I’m not sure why).  Well, now the Departments have addressed the issue, and while it is still inconclusive, I don’t think the end result looks pretty. Today, the Departments issued another round of guidance – called Part III on the DOL website.  The Departments state that they are analyzing the separate versus one ERISA plan issue for the retiree… Continue Reading