Employers And Health Reform: Do You Know What Your Current Obligations Are?

Although any changes that flow from the Patient Protection and Affordable Care Act, as amended by the Health Care and Education Reconciliation Act (collectively, “PPACA”), will not phase in for years, others took effect on September 23, 2010. A short description of the provisions that took effect on that date, as well as regulations issued recently by various agencies, is provided below.

Annual and Lifetime Limits

One of the most significant new provisions regards lifetime and annual limits for “essential health benefits” for participants and beneficiaries. Lifetime limits are precluded completely. For plan years beginning on or after September 23, 2010, group health plans and insurance companies may not establish annual limits under $750,000. this ceiling increases to $1.25 million for plan years beginning on or after September 23, 2011 and to $2 million for plan years beginning on or after September 23, 2012. From January 1, 2014 forward, any annual limit is precluded.