Posts Tagged: mini-med

Insured Nondiscrimination Rule Compliance Delayed

in Affordable Care Act

This evening the IRS released Notice 2011-1, exempting insured plans from the new nondiscrimination rules in the Affordable Care Act (and related penalties for non-compliance) until regulations are issued. Further, the notice provides that the regulations are expected to apply to plan years beginning after issuance. Meaning that for calendar year plans, the earliest the nondiscrimination rules should apply is January 1, 2012. It could even be later than that depending on when the IRS issues the nondiscrimination regulations, which is currently expected in Q2 or Q3 of 2011. (The new nondiscrimination rules do not apply to insured grandfathered plans.)… Continue Reading

Additional Annual Limit Waiver Guidance

in Affordable Care Act

OCIIO updated its annual limit or mini-med waiver guidance this afternoon.  Among the recent items is guidance concerning model notices that are required to be sent by plan sponsors who obtain an annual limit waiver, along with a fact sheet, consumer information and restrictions on new “mini-med” plans.  Additional information is posted at

HHS Issues MLR Interim Final Rules

in Affordable Care Act

This morning HHS issued the long-awaited MLR interim final regulations.  In prior posts, I discussed that insured mini-med plans and insured expatriate plans have been asking for an exception from these new requirements.  Unfortunately, the interim regulations do not contain a blanket exception.  However, the interim regulations do require an insurer to seperately report aggregate premium and expenditure data for expatriate plans and mini-med plans.  (Mini-med is defined by HHS as a plan that has less than a $250,000 annual individual limit.)  In order to address the special circumstances of mini-med and expatriate plans, the interim final regulations then apply a… Continue Reading