Employee Benefits Compliance

RECENT HEALTH CARE REFORM UPDATES: as of May 16, 2011

No employer action is required for any of these items. This Bulletin summarizes what’s been happening recently with Health Care Reform: Repealed, Delayed, Recent Guidance, Court Actions and Waivers. Following the outline below is a brief summary of each of the items.

Repealed:
* Free Choice Vouchers
* Consumer Operated and Oriented (CO-OP) Plan Program
* Expanded 1099 Reporting Requirement

Delayed:
* Effective date of HCR’s New Internal Claims and Appeals Procedures
* Effective Date of W-2 Reporting of Cost of Group Health Coverage, for Small Employers

Guidance and Request for Public Comments:
* IRS Notice 2011-36, Solicits Public Comment on the Shared Responsibility Provisions of HCR
* HCR FAQs Part VI: Examples of Changes that Will/Will Not Cause Loss of Grandfather Status
* DOL Request for Information Regarding Electronic Disclosure by Employee Benefit Plans

Court Action:
* Supreme Court: No Expedited Review of Virginia District Court Case
* Court Action: Five Appeals Courts Will Hear Appeals of HCR Cases
* DC District Court: Upheld Constitutionality of the Individual Mandate

Waivers:
* State Waivers from HCR Provisions
* State Waivers/Adjustments from Medical Loss Ratio (MLR) provisions
* Plan/Carrier Waivers from HCR’s Restricted Annual Limits Requirements