SIIA PPACA Update – 09/08/10
SIIA, www.siia.org
As reported by SIIA’s Government Relations Staff, Federal agencies will be continually issuing regulations and notices of guidance pertaining to how provisions of the newly enacted Patient Protection and Affordable Care Act will be implemented. SIIA staff will develop summaries of these and distribute along with the full documents as soon as they are released.
Department of Health and Human Services Releases Bulletin Outlining the Waiver Process for “Mini-Meds” for Exemption from the Annual Limits Prohibition
While the PPACA places a new prohibition on group health plans from imposing annual dollar limits on TBD “essential health benefits”, the released bulletin provides an exemption from this provision for limited benefit plans, or “mini-meds”.
Plans may apply for a waiver from the restricted annual limits if such plan was offered prior to September 23, 2010 for the plan year beginning between September 23, 2010 and September 23, 2011. Plans would have to submit the waiver request no later than 30 days prior to the start of the plan year. Plans whose plan year begins prior to 11/2/10, only need to submit the request no later than 10 days prior.
The application must include:
The terms of the plan or policy form(s) for which a waiver is sought;
The number of individuals covered by the plan or policy form(s) submitted;
The annual limit(s) and rates applicable to the plan or policy form(s) submitted;
A brief description of why compliance with the interim final regulations would result in a significant decrease in access to benefits for those currently covered by such plans or policies, or significant increase in premiums paid by those covered by such plans or policies, along with any supporting documentation; and
An attestation, signed by the plan administrator or Chief Executive Officer of the issuer of the coverage, certifying 1) that the plan was in force prior to September 23, 2010; and 2) that the application of restricted annual limits to such plans or policies would result in a significant decrease in access to benefits for those currently covered by such plans or policies, or a significant increase in premiums paid by those covered by such plans or policies.
Plans are required to reapply for the waiver each year. Future regulations will detail whether or not this waiver will be available to plans beyond 2014.
Plans seeking the waiver should submit the required information, in the proper required timeline to Office of Consumer Information and Insurance Oversight at HHS.
Stay Informed on the PPACA
SIIA’s Government Relations Staff is continually updating SIIA’s PPACA In-Depth Analysis as regulations and guidance are issued by Federal agencies and Congress. Please continue to visit our website to review the most up-to-date information – http://www.siia.org/i4a/pages/index.cfm?pageID=5401.
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