Health care reform: Guidance issued on notice requirements
The federal agencies in charge of issuing guidance on the federal Affordable Care Act’s requirements have been busy.
The federal agencies in charge of issuing guidance on the federal Affordable Care Act’s requirements have been busy. Updates on three different notice requirements have been issued recently:
• Model COBRA Election Notice: The U.S. Department of Labor (DOL) has updated its model COBRA election notice to inform COBRA qualified beneficiaries that, as of January 1, 2014, alternatives to COBRA coverage are available through the exchange marketplace and premium tax credits may be available to pay for such coverage. Furthermore, special enrollment opportunities may exist in other group health plans and pre-existing condition limitations will be limited, and then prohibited, beginning in 2014. The updated notice also removes outdated information in the prior model COBRA election notice. While it is not required that employers use this model, Vigilant recommends that you do, and you may begin using this updated notice for COBRA compliance now. Be sure to customize the model for use with your particular employee benefit plans. For more information on COBRA notice requirements, check out our Legal Guide, “COBRA Qualifying Events and Notice Schedule” (1658).
• Summary of Benefits and Coverage (SBC): A new model SBC template is now available for use in the 2014 plan year. This new model contains minor changes from the previous version. Note that, for insured group health plans, your insurance carrier most likely handles the SBC requirement for you.
• Model Notice of Marketplace Coverage Options: The DOL has issued a model Notice of Marketplace Coverage Options, informing employees of the existence of the exchange marketplace, that they may be eligible for premium tax credits to purchase coverage through the exchange, and that if they purchase coverage through the exchange, they may lose the employer contribution (if any) toward employer-sponsored coverage. This notice must be distributed to all current employees and new hires, beginning October 1, 2013. Two model notices are provided, one for employers who do not offer employee healthcare coverage, and one for employers who offer employee health coverage.
Questions? Find out more about ongoing counsel on Health Care Reform through Vigilant. 800-733-8621.