Grandfathered Health Plan Regulations
The U.S. Departments of the Treasury, Labor, and Health and Human Services recently issued long-anticipated Interim Final Rules defining the term “grandfathered health plan” and clarified other health care reform requirements. Various mandated benefit requirements of the Patient Protection and Affordable Care Act, as amended by the Health Care and Education Reconciliation Act of 2010, apply differently to grandfathered health plans than to non-grandfathered plans. Employers will need to carefully review their benefit plan offerings to determine whether the benefits of maintaining grandfathered status outweigh the restrictions on plan design and cost-sharing imposed by these Interim Final Rules.
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