National Health Care Reform Legislation - Review of Initial Guidance.

Mondaq Business BriefingNbr. 2010, January 2010

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National Health Care Reform Legislation - Review of Initial Guidance.

We previously reported on the recently enacted health care reform legislation, under the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010 (for purposes of this Alert, these Acts will be referred to collectively as "PPACA"), which, among other things, significantly altered employer responsibilities with respect to providing group health plan coverage to employees. A copy of our earlier Alert can be found at http://www.pbwt.com/resources/publications/navigating-health-care-reform/.

This Alert describes recent guidance that has been issued with respect to PPACA's provisions regarding extended coverage for adult children, an available small employer subsidy and a temporary reinsurance reimbursement program for early retirees.

At the time of the writing of this Alert interim final regulations were issued with respect to PPACA's rules regarding "grandfathered" plans, and some of the other changes made by PPACA. We anticipate issuing a follow-up Alert on those regulations, as well as one or more follow-up Alerts highlighting important PPACA provisions that become effective after 2011, including PPACA's provisions imposing penalties imposed on large employers who do not offer health coverage to full-time employees and the "Cadillac" tax.

I. Extended Coverage of Adult Children.

As we discussed in our prior Alert, the new PPACA rules regarding coverage of employees' adult children require group health plans to continue to make coverage available to adult children until the children attain age 26.1 While group health plans are not required to offer extended coverage prio...

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