Posts Tagged: Insured Plans

Nondiscrimination for Insured Plans – Update

in Affordable Care Act

A few weeks ago we informed you of the delay in regulations regarding the insured plan nondiscrimination rules.  Yesterday, the IRS published Notice 2010-63, requesting information regarding how the new nondiscrimination rules should apply to insured plans and the interaction with 105(h).  Comments are due by November 4, 2010.  The IRS is likely looking at how it can combine nondiscrimination testing when a single sponsor has multiple insured options and/or multiple insured and self-insured options.  Based on the timing for comments, i would not expect regulations to be issued until the early part of 2011.  Link to Notice 2010-63 is as… Continue Reading

Nondiscrimination for Insured Plans

in Affordable Care Act

New PHSA Section 2716 adopts new nondiscrimination rules on insured health plans beginning with the first plan year after September 23, 2010 (or January 1, 2011 for calendar year plans). The statute provides that rules similar to the Code Section 105(h) rules for self-insured plans shall apply for this purpose. We thought that the regulations implementing this new requirement were to be released soon. However, last week we heard, unofficially, that the regulations have been delayed, meaning that employers with insured plans have no idea whether their health plans will satisfy the new regulations when annual enrollment season begins next month…. Continue Reading