Health Care Alert: Navigating Health Care Reform (October 14, 2010)
Restructuring Tiers of Coverage or Making Changes to Wellness Incentives May Impact Grandfathered Plan Status
The Departments of Health and Human Services, Labor and Treasury issued more FAQs on Friday, October 8, addressing the impact of certain plan design changes on grandfathered plan status under the Patient Protection and Affordable Care Act, as amended by the Health Care and Education Reconciliation Act of 2010 (collectively, the "Act"). Grandfathered plans, which are group health plans that were in existence on March 23, 2010, have to comply with some, but not all, of the requirements under the Act. Significant changes that reduce benefits or increase participant costs will cause a plan to lose grandfathered status. If you have restructured tiers of coverage or changed wellness benefits for the upcoming plan year, your grandfathered plan status may be in jeopardy.