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New FAQ on Waiting Periods

Originally posted by United Benefit Advisors (UBA)

The 90-day maximum for eligibility waiting periods is effective as of the start of the 2014 plan year.  As employers are beginning to implement this new requirement, many have questions.  Kaminsky & Associates has created a PPACA Advisor that addresses a number of recurring questions about this new provision.

PDF version of the FAQ may be accessed here.   Kaminsky & Associates will distribute an employer-facing version shortly. HCR Central has updated several PPACA Advisor pieces.  All of these updates are available in HCR Central.

The updates to the Individual Responsibility document include:

  • Recent relaxation of the individual mandate requirements for some (the delay on the individual mandate fee for individuals who enroll in the marketplace by March 31, 2014, and the ability of those who had individual coverage cancelled and who cannot find reasonably priced replacement coverage to obtain a hardship exemption for 2014)
  • The regulatory agencies’ determination that a health reimbursement arrangement (HRA) with a balance is minimum essential coverage
  • A clear statement that dependents are not eligible for a premium subsidy if the cost of employee-only coverage is affordable and the dependents are eligible for the employer-provided coverage, even if the cost of family coverage exceeds 9.5% of income

The updates to the Common Terms piece include more information on how essential health benefits (EHBs) are determined and how self-funded plans are affected by EHBs, the regulatory agencies’ determination than an HRA is minimum essential coverage and the effect of having minimum essential coverage on eligibility for a premium subsidy.  The updates also reflect the delay in the “play or pay” requirements until 2015 and the choice of all states to define a small employer, for purposes of the insurance market, as fewer than 50 employees for 2014.

The updates to the PPACA Fees Highlight are fairly minor and primarily address the ability to pay the Transitional Reinsurance Fee (TRF) in two parts and the anticipated fee of $44 per covered life for 2015.  The updated chart includes these changes and emphasizes that, unlike the Patient Centered Outcomes Research Institute (PCORI) fee, only one TRF fee will be due per person (owed by the entity that provides major medical coverage).

The updates to the FAQ on Grandfathered Plans are just for readability.