Employers

Last Updated: 12/29/11

ROPES & GRAY ANALYSIS

• Compliance Date Postponed for Insured Group Health Plan Discrimination Rules
  (December 23, 2010)
   
• Employer Specific Timeline
   
• Federal Agencies Issue Interim Final Rules for the Patient's Bill of Rights
  (June 24, 2010)
   
• Federal Agencies Issue Interim Final Rules for Grandfathered Health Plans
  (June 16, 2010)
   
• Health Reform Law Implementation Begins
  (April 15, 2010)
   
• Health Care Reform's Impact on Employers and Group Health Plans
  (April 2, 2010)
   
• Health Care Legislation Yields Significant Tax Consequences
  (March 26, 2010)

IMPLEMENTING REGULATIONS AND GUIDANCE

• IRS Issued Notice 2012-9 Interim Guidance of Informational Reporting to Employees of the Cost of Their Group Health Insurance Coverage
  (January 3, 2012)

• DOL Proposes Rules for Multiple Employer Welfare Arrangements
  (December 5, 2011)

• DOL Technical Release 2011-04 on Rebates for Group Health Plans Paid Pursuant to Medical Loss Ratio Requirements
  (December 2, 2011)

• DOL FAQS About Affordable Care Act Implementation Part VII and Mental Health Parity Implementation
  (November 17, 2011)

• IRS Issued Notice 2011-73 Request for Comments on Health Coverage Affordability Safe Harbor for Employers
  (September 13, 2011)

• Proposed Template: Summary of Benefits and Coverage and Uniform Glossary – Templates, Instructions, and Related Materials under the Public Health Service Act
  (August 17, 2011)

• Proposed Regulations: Summary of Benefits and Coverage and the Uniform Glossary
  (August 17, 2011)

• Proposed Rule: Patient Protection and Affordable Care Act; Exchange Functions in the Individual Market: Eligibility Determinations; Exchange Standards for Employers
  (August 12, 2011)

• Final Rule: Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services Under the Patient Protection and Affordable Care Act
  (August 3, 2011)

• Amendment to Final Rule: Group Health Plans and Health Insurance Issuers: Rules Relating to Internal Claims and Appeals and External Review Processes
  (June 24, 2011)

• DOL Technical Release 2011-02: Guidance on External Review for Group Health Plans and Health Insurance Issuers Offering Group and Individual Health Coverage, and Guidance for States on State External Review Processes
  (June 22, 2011)

• IRS Request for Comments on Shared Responsibility for Employers Regarding Health Coverage
  (May 3, 2011)

• Labor Department Survey of Employer-Sponsored Health Plan Coverage
  (April 15, 2011)

• DOL FAQS on Affordable Care Act Implementation Part VI

• Notice 2011-28: Interim Guidance on Informational Reporting to Employees of the Cost of Their Group Health Insurance Coverage 
  (March 29, 2011)

• DOL Technical Release 2011-01: Extension of Non-Enforcement Period Relating to Certain Interim Procedures for Internal Claims and Appeals under the Patient Protection and Affordable Care Act
  (March 18, 2011)

• Request for Information Regarding Value-Based Insurance Design in Connection with Preventive Care Benefits
  (December 28, 2010)

• Notice 2011-15:  Guidance on Use of FSA Debit Cards for Over-the-Counter Drugs
  (December 27, 2010)

• Notice 2011-1: Timing of Affordable Care Act Nondiscrimination Provisions Applicable to Insured Group Health Plans
  (December 22, 2010)

• Notice 2011-02:  Guidance on the Application of Section 162(m)(6)
  (December 22, 2010)

• DOL FAQS About Affordable Care Act Implementation Part V and Mental Health Parity Implementation
  

   
• DOL FAQS on Affordable Care Act Implementation Part IV
   
• FAQS on Affordable Care Act Implementation III
   
• Notice Providing Interim Relief on Reporting Cost of Group Health Insurance Coverage
  (October 12, 2010)
   
• Draft W-2
  (October 12, 2010)
   
• IRS Releases Notice 2010-63: Request for Comments on Requirements Prohibiting Discrimination in Favor of Highly Compensated Individuals in Insured Group Health Plans
  (September 20, 2010)
   
• DOL, HHS, and Treasury Technical Release 2010-02: Interim Procedures for Internal Claims and Appeals under the Patient Protection and Affordable Care Act
  (September 20, 2010)
   
• DOL FAQS: Affordable Care Act Implementation
  (September 20, 2010)
   
• Draft Version of Form 8941 for Calculating the Small Business Health care Tax Credit
  (September 7, 2010)
   
• IRS Issues Guidance Explaining 2011 Changes to Flexible Spending Arrangements
  (September 3, 2010)
   
• IRS Notice 2010-59: Guidance on § 9003 of PPACA (Revising the definition of medical expenses as it relates to over-the-counter drugs)
  (September 3, 2010)
   
• IRS Revenue Ruling 2010-23: Guidance on employer reimbursements of amounts paid by an employee to purchase nonprescription medicines or drugs
  (September 3, 2010)
   
• Issue Interim Procedures for Federal External Review
  (August 23, 2010)
   
• Technical Release 2010-01 Interim Procedures for Federal External Review
  (August 23, 2010)
   
• Pre-Existing Condition Insurance Plan Program
  (July 30, 2010)
   
• Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Internal Claims and Appeals and External Review Processes
  (July 22, 2010)
   
• Fact Sheet: Internal Claims and Appeals and External Review Processes
  (July 22, 2010)
   
• Interim Final Rules for Group Health Plans and Health Insurance Issuers Relating to Coverage of Preventive Services under the Patient Protection and Affordable Care Act
  (July 19, 2010)
   
• Recommendations: Guidance for Insurance and Medical Professionals
  (July 14, 2010)
   
• Model Notice on Lifetime Limits 
  (July 1, 2010)
   
• Model Notice on Patient Protections 
  (July 1, 2010)
   
• Model Notice for Extension of Dependent Coverage to Age 26
  (July 1, 2010)
   
• HHS: Early Retiree Reinsurance Program Application
  (June 30, 2010)
   
• HHS: Early Retiree Reinsurance Program Application Instructions
  (June 30, 2010)
   
• HHS: FAQs: Early Retiree Reinsurance Program
  (June 30, 2010)
   
• HHS Q&A: Grandfathered Health Plans
  (June 14, 2010)
   
• HHS Fact Sheet: Grandfathered Health Plans
  (June 14, 2010)
   
• IRS: Affordable Care Act Tax Provisions
   
• HHS: Draft Application for Early Retiree Reinsurance Program
   
• IRS: Interim Final Rule on Grandfathered Health Plans
  (June 11, 2010)
   
• IRS Guidance: Tax Credit for Employee Health Insurance Expenses of Small Employers
  (May 20, 2010)
   
• IRS, DOL, HHS: Interim Final Rules for Insurance Coverage for Dependents to Age 26
  (May 10, 2010)
   
• White House Fact Sheet: Young Adults and the Affordable Care Act
  (May 10, 2010)
   
• HHS Interim Final Rule: Early Retiree Reinsurance Program
  (April 29, 2010)
   
• IRS: Guidance on Tax Treatment for Children up to Age 27 under the Affordable Care Act
  (April 27, 2010)
   
• White House Fact Sheet: Early Benefits from the Affordable Care Act of 2010 Reinsurance Program for Early Retirees
  (April 12, 2010)
   
• IRS Guidance: Small Employer Tax Credit
  (April 1, 2010)

ANALYSIS PRIOR TO PASSAGE