In their recent Webinar on Healthcare Reform, attorneys Doug Seaton and Emily Ruhsam focus on nine key changes that take effect on January 1, 2011 (for calendar year health plans):
- Non-grandfathered plans must provide for certain internal appeals procedures (including an external review process).
- Non-grandfathered plans must cover certain preventative services (i.e., immunization and infant screenings) without cost sharing.
- Non-grandfathered, fully insured plans must undergo non-discrimination testing (currently a requirement for self-insured plans only). This is similar to the top-heavy discrimination testing for 401(k) plans.
- Plans that offer dependent coverage must offer coverage until age 26 (grandfathered plans must cover such dependents only if the dependent is not eligible for other employer-sponsored coverage).
- Prohibits pre-existing condition limitations for children under 19.
- Abolishes lifetime limits on minimum essential benefits.
- Prohibits “unreasonable” annual limits on minimum essential benefits.
- Prohibits recession (cancellation) of participants.
- Prohibits reimbursement of over-the-counter medications (without a physician prescription through a Health Flexible Spending Account, Health Reimbursement Account, Health Savings Account, or Archer Medical Savings Account).
HR That Works members can watch the Webinar and read the complete report on HR That Works.