Just when you thought you had all of the grandfathering rules figured out, yesterday the U.S. Department of Health & Human Services issued the following Amendment to Interim Final Regs on Status as Grandfathered Plan under PPACA. Here is an excerpt – published today in the Federal Register:
“This amendment modifies . . . the interim final regulations, which previously caused a group health plan to cease to be a grandfathered health plan if the plan entered into a new policy, certificate, or contract of insurance. The modification provides that a group health plan does not cease to be grandfathered health plan coverage merely because the plan (or its sponsor) enters into a new policy, certificate, or contract of insurance after March 23, 2010 (for example, a plan enters into a contract with a new issuer or a new policy is issued with an existing issuer). The amendment applies to such changes to group health insurance coverage that are effective on or after [November 15, 2010], the date the amendment to the interim final regulations was made available for public inspection;”
If you have any questions about what this means to you and/or your group plan, don’t hesitate to ask.
If your eyes begin to cross while trying to read the full amendment, here is a 2 page Fact Sheet summarizing the Amendment.
The gist: You can now change carriers and maintain grandfathered status.