The one-year anniversary of the Patient Protection and Affordable Care Act has come and gone, and federal agencies continue to issue clarifying guidance on several of its provisions, including the grandfathered health plan rules and the requirement to report the cost of employer-provided health coverage on employees’ Forms W-2.
On April 1, the Departments of Labor, Health and Human Services, and Treasury released a sixth set of frequently asked questions regarding PPACA’s grandfathered health plan rules. A grandfathered health plan is a group health plan or individual health insurance coverage in which at least one individual was enrolled on March 23, 2010. Grandfathered health plans are exempt from many, but not all, of the PPACA mandates. For instance, grandfathered health plans are not required to comply with the nondiscrimination testing requirements applicable to fully insured plans or the new appeals process rules under PPACA.
