Employers — particularly those that sponsor self-funded plans — have important health care reform mandates to comply with in January 2014, many of which are unaffected by the Obama administration’s stay in enforcement of the pay-or-play rules. There is still time for employers to get their health care reform fixes right. The job is more difficult for some plans than it is for others.
Self-funded health plans have the most complicated task. They have enjoyed the privilege of not complying with the coverage mandates that insurers had to comply with in 2010. But the party’s over. Starting in 2014, they will have to: (1) observe new out-of-pocket limits; (2) start covering preventive care without cost-sharing; (3) eliminate all annual and lifetime limits; and (4) begin covering dependent children on plans (if they cover them at all) until they turn 26 without exception.
All employers — whether self-funded or insured and regardless of number of employees — can take no more than 90 days to enroll eligible individuals into company health plans, also starting in 2014. Many plans could be complying with this for the first time. It involves counting days to observe the limited waiting periods, obviously, but it may also involve counting full-time versus part-time workers, and tracking hourly versus salaried workers, because they can be subject to different waiting periods too (as long as none exceeds 90 days).
Finally, employers would be well-advised to get used to rules on counting full-time workers, “full-time equivalents,” understanding use of safe harbor “look-back” periods and knowing about other aspects of health care reform’s pay-or-play rules, in spite of the enforcement stay until January 2015.
On Nov. 19, from 2:00 until 3:30, Eastern Time, you can tune into a 90-minute interactive webinar, entitled The Ever-Changing World of Health Care Reform: Planning Ahead for 2014, for detailed answers on clearing these obstacles. The webinar, sponsored by Thompson Information Services (which also sponsors this blog) will give you practical answers to help you to overcome these administrative challenges.
Our extremely well-informed and supremely capable speakers will be Paul M. Hamburger, a partner in the Washington, D.C., office of Proskauer Rose LLP; and James R. Napoli, a Senior Counsel in the same law offices. They are managing author and senior contributing editor, respectively, of The New Health Care Reform Law: What Employers Need to Know, published by Thompson Information Services.