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Final Regulations on Orientation Periods Released
Decision Applies to All Groups
The Federal regulatory agencies have provided a final regulation on allowing orientation periods, which is welcome news to groups of all sizes. California usurped the federal enrollment period requirement of 90 days and has mandated that eligible employees be enrolled within 60 days from date of hire. The orientation period would allow a one month period, not to exceed 30 days, to evaluate employees prior to the start of the waiting period. The orientation period and the waiting period combined may not exceed 90 days. Our legal team at Proskauer Rose LLP has confirmed that the ruling can be retroactive to your health insurance plan anniversary date in 2014. The challenge will come on the administrative side with the carriers as they will need to be on-board with this change in order to process eligibility appropriately. Carrier systems are all driven to calculate eligibility from the date of hire and the waiting period. They will need to develop systems to accommodate the addition of an introductory period when determining a member's effective date for benefits. This will prove easier in large group than in small group. Please read our latest blog post for the full story.
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SB1446: "Grandmothering" in Small Group Contracts
When contracts change, coverage can change as well
On Monday, July 7, 2014, Governor Brown signed new legislation which permits insurance carriers to extend pre-ACA small group medical plans through December 2015. The Bill, SB1446 give carriers the option, but does not require them to extend pre-ACA plans, referred to as "Grandmothering" for many small group carriers renewing on or after September 2014. An employer may likewise accept or decline the offer. Read more...
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For Groups Over 50
Transitional relief is on our mind and many of yours as we move into the third and forth quarters.
Employers that employ between 50 and 99 full-time and full-time equivalent employees are not required to offer coverage until the first day of their plan year starting in 2016 if they meet certain requirements.
Employers with 100 or more full-time and full-time equivalent employees will need to offer coverage to 70% of their full-time employees in 2015 to avoid a penalty. If an applicable larger employer with 100 or more full-time and full-time equivalent employees is subject to a penalty for failing to offer coverage, then the penalty will be calculated by reducing the number of full-time employees by 80 rather than 30. If the applicable large employer is a member of a controlled group, then the number is reduced by the employer's allowable share of 80. Read more...
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