ACA Regulations Finalized, Additional Guidance Issued: Employment Law Manual Updated, Legal Timetable Entry Added
Author: Tracy Morley, XpertHR Legal Editor
Comprehensive final rules under the Affordable Care Act (ACA) published by the Departments of Labor, Health and Human Services and Treasury clarify and adopt interim rules pertaining to:
- Grandfathered plan status;
- Pre-existing condition exclusions;
- Lifetime and annual dollar limits;
- Dependent coverage;
- Patient protections; and
- Health reimbursement accounts.
The final rules do not substantially change the interim rules and will apply beginning on the first day of the first policy or plan year that begins on or after January 1, 2017.
In addition, the Internal Revenue Service has provided guidance on the ACA pertaining to:
- The adjusted no-coverage and unaffordable/inadequate coverage penalties for 2015 and 2016 under the employer mandate;
- The rate used to determine whether a health plan provides minimum value for the 2015 and 2016 plan years;
- The application of ACA market reforms to health reimbursement arrangements (HRAs) and to employer reimbursements for individual health insurance premiums;
- Employee contributions when an employer offers opt-out payments, flex contributions or HRAs;
- Consolidated Omnibus Budget Reconciliation Act (COBRA) coverage and unused amounts in health flexible spending accounts; and
- Hours of service for determining full-time employee status.