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Ascentis Blog - Information to help HR and payroll managers, recruiters, and compliance officers become more effective.

Health Care Reform Checklist for 2011

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The Patient Protection and Affordable Care Act (PPACA) contains comprehensive health insurance reforms that require compliance by employer-sponsored group health plans. Many of these reforms apply to plan years beginning on or after September 23, 2010. The following general checklist is designed to help employers review their plan’s compliance with the major health care reform requirements implemented in 2010, as well as prepare for changes ahead in 2011.

Please note that this list is for general reference purposes only and is not all-inclusive. This list is also subject to change based on new government requirements or directives. Additionally, your group plan may be exempt from certain requirements described below. If you have any questions regarding your
obligations with respect to health care reform, you should consult with a knowledgeable employment law attorney and your carrier for specific guidance.

1. Determine Grandfathered or Non-Grandfathered Status of Plan


Note: A grandfathered plan is one that was in effect on March 23, 2010. If a plan loses its grandfathered
status, it may no longer be exempt from certain PPACA requirements.

  • Evaluate whether any changes made to the group health plan with respect to benefits,
    costs, or other changes result in
    loss of grandfathered status.
  • To maintain grandfathered status, a plan must include a statement, whenever a summary of benefits
    under the plan is provided to participants and beneficiaries, that the plan believes it is a grandfathered
    health plan according to the Affordable Care Act and must provide contact information for questions and
    complaints (model notice available here).

2. Review Plan Documents for Required Changes

Note: Unless otherwise noted, plan documents should be amended to reflect changes effective as of the
first day of the first plan year beginning on or after September 23, 2010. Please consult with your
carrier for additional details or if you have questions regarding these amendments.

3. Implement Special Enrollment Opportunities

Note: The following special enrollment opportunities must be provided, and coverage must take effect,
not later than the first day of the first plan year beginning on or after September 23, 2010.

4. Provide Participant Notices

Note: Unless otherwise noted, the following notices should be provided to plan participants no later than the first day of the first plan year beginning on or after September 23, 2010.

5. Other Considerations

Please note that employers in some states may be required to report the cost of employer-provided health benefit coverage for adult children on the employee’s Form W-2 in 2011 for state income tax purposes. Employers should contact their state revenue department for reporting requirements related to coverage for adult children.

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