Like Santa, I imagine you’ll be making a list and checking it twice (20 times?) to make sure you have all your talking points in order so you can communicate effectively to employees how the
(You might even envy Santa, in that he only has to check his list for young children, not adults up to age 26!)
At any rate, to help you ensure you communicate anything and everything, Mercer’s developed a list of what you’ll want to do and say before enrollment season kicks off this fall — and surely before many PPACA provisions take effect for plan years beginning on or after Sept. 23 (for most plans, Jan. 1, 2011). Take notes, pros. Here’s what to do if you have:
- Plans providing dependent coverage.
• 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 first day of plan year
- Plans eliminating lifetime dollar limits.
• Expressly state in writing that plan has no lifetime dollar limit and that persons previously affected by a limit are again eligible for coverage
• Provide 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 first day of plan year
- Plans imposing per-beneficiary limits.
• Describe essential health benefits and permitted per-beneficiary annual limit ($750,000 for 2011)
• Describe nonessential health benefits and permitted per-beneficiary annual limit
- Plans with pre-existing condition exclusions.
• Delete all references to preexisting condition exclusions for children under age 19
- Plans offering tax-advantaged accounts (FSAs, HSAs, HRAs or Archer MSAs).
• Explain new limits on reimbursements for over-the-counter medications
• Explain nonqualified distribution penalties for HSAs and Archer MSAs (optional)
- Nongrandfathered plans.
• Delete cost-sharing for preventive services
• Delete preauthorization requirements for emergency services and referrals for OB/GYN services
• If designation of primary care provider required, ensure that participants have adequate range of choices
- Employers participating in CLASS program*:
• Describe program and costs
• Provide automatic enrollment and facilitate payroll deductions
- Plan cancellation conditions:
• Update communications to describe cancellation practices meeting new standards
• Even in cases where rescission is permitted, plans must provide participants with written notice at least 30 days before coverage is terminated.
Does this checklist have you feeling more secure about this year’s enrollment season? Or, are you ready to pack it up and move in with Santa at the North Pole? Share your thoughts in the comments.
*Please read