Healthcare Reform
For a complete overview of the impact of healthcare reform on dealerships, watch our free recorded webinar: What Healthcare Reform Means for Dealers.
Limitations on Preexisting Conditions
On June 28, 2010, the Departments of Health and Human Services, Labor and Treasury, published interim final regulations ("Interim Regulations") pertaining to the preexisting condition exclusions, lifetime and annual dollar limits, rescissions, choice of providers, and coverage of emergency services requirements under the Patient Protection and Affordable Care Act, as amended by the Health Care and Education Reconciliation Act (the "Act"). Most of the Interim Regulations are effective for plan years beginning on or after September 23, 2010, which means an effective date of January 1, 2011 for calendar year plans. The prohibition of preexisting condition exclusions for individuals under the age of 19, has the above effective date, but that prohibition is not applicable to all other individuals until January 1, 2014. With the exception of the patient protections (choice of providers and coverage of emergency services requirements), the Interim Regulations apply to both grandfathered and non-grandfathered group health plans.
Clarification on Rules for Preventive Services
Under the health care reform law, non-grandfathered plans must provide preventive services on a first dollars basis (without any cost-sharing requirements – co-pays, deductibles, or co-insurance) beginning with the first plan year on or after September 23, 2010 (January 1, 2011 for calendar year plans). The regulations clarify what preventive services must be covered (called "recommended preventive services"), how cost-sharing applies when recommended preventive services are billed with an office visit, that there is no cost-sharing prohibition for out-of-network providers, and the timing for which coverage must be provided when guidelines change.
Recommended Preventive Services
A complete list of the preventive services that must be covered can be found at:
http://www.healthcare.gov/center/regulations/prevention/recommendations.html
Agencies Issue Interim Final Rules Concerning Dependent Coverage
On May 10, 2010, the Employee Benefits Security Administration ("EBSA") of the Department of Labor, along with the Departments of the Treasury and Health and Human Services released Interim Final Rules implementing the extension of dependent coverage for children up to age 26, as required by the Patient Protection and Affordable Care Act ("PPACA" or "health care reform"). The EBSA also released a Fact Sheet and Frequently Asked Questions ("FAQs") that describe the extension of dependent coverage. The Interim Final Rules can be viewed at the following website: http://www.dol.gov/ebsa/pdf/dependentcoverage.pdf. The EBSA's Fact Sheet is available at: http://www.dol.gov/ebsa/newsroom/fsdependentcoverage.html, and the FAQs are available at: http://www.dol.gov/ebsa/faqs/faq-dependentcoverage.html.
HSA Contribution Limit Remains Unchanged for 2011
The IRS has announced that the 2011 inflation adjusted amounts for Health Savings Accounts (HSAs) will remain unchanged from the 2010 amounts because after the application of the cost-of-living adjustment rules, the changes in the Consumer Price Index for the relevant period do not result in changes to the amounts for 2011.
Annual Contribution Limits for 2011
Individual with Self-Only Coverage under High-Deductible Health Plan: $3,050 Individual with Family Coverage under High-Deductible Health Plan: $6,150
High Deductible Health Plan
For 2011, a high deductible health plan is a health plan with an annual deductible that is not less than $1,200 for self-only coverage or $2,400 for family coverage, and the out-of-pocket expenses (deductibles, co-payments, and other amounts, but not premiums) do not exceed $5,950 for self-only coverage or $11,900 for family coverage.
For additional information, download our free recorded webinar on The Impact of Healthcare Reform on Dealerships and also see the August issue of the KPA Compliance Newsletter.
Stay on top of ever changing HR regulations and compliance requirements with the HR Regulatory Update, KPA Compliance Newsletter and free live and recorded webinars. The HR Regulatory Update is provided in conjunction with KPA partner, Ford & Harrison LLC, a labor and employment law firms with a national practice in all aspects of labor and employment law, providing HR advice to HotlinkHR™ clients. http://www.fordharrison.com
