In its latest Update for its U.S. Health Care Reform Series, Mercer says complying with new health care reform provisions will require careful planning, revisions to open enrollment materials and employee communications, and coordination with vendors to ensure that far-reaching changes are thoroughly implemented. The update provides a good checklist for plan sponsors to get started now.
For plans providing dependent coverage up to age 26, Mercer suggests sponsors:
- Describe adult child eligibility (including restrictions, if grandfathered plan);
- Provide prominent written notice of special enrollment opportunity;
- Offer special enrollment opportunity of at least 30 days (may run concurrent with open enrollment period);
- Make coverage effective as of the first day of plan year.
Plan sponsors eliminating lifetime dollar limits should expressly state in writing that plan has no lifetime dollar limit and that persons previously affected by a limit are again eligible for coverage, as well as provide written notice of special enrollment opportunity and offer a special enrollment opportunity of at least 30 days.
In addition, Mercer said plan sponsors imposing per-beneficiary limits should describe essential health benefits and permitted per beneficiary annual limit, and describe nonessential health benefits and permitted per beneficiary annual limit. Plans with pre-existing condition exclusions must delete all references to preexisting condition exclusions for children under age 19.
Plans sponsors offering tax-advantaged accounts (FSAs, HSAs, HRAs, or Archer MSAs) should explain new limits on reimbursements for over-the-counter medications and explain nonqualified distribution penalties for HSAs and Archer MSAs (optional).
More insights from Mercer can be found at http://www.mercer.com/us-health-care-reform.In addition, Mercer will be hosting a Webcast on July 15 titled “Open enrollment after health care reform.” To register, go to http://www.mercer.com/webcasts.
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