Implementation of Health Care Reform

Since it became effective on September 23, 2010, implementation of the Patient Protection and Affordable Care Act of 2010 (Public Law 111-148), as amended by the Health Care and Education Reconciliation Act of 2010 (Public Law 111-152) continues apace.  Despite multiple legal challenges to health care reform, federal agencies tasked with insuring timely compliance continue to write regulations that must be addressed by employers, health plans, insurers and others impacted by these massive changes to our health care delivery system.  First, a refresher on some of the things still to be done:


Grandfathered  and Non-grandfathered Plans

  • Advance Notice of Changes in Benefits and Coverage – Employers must distribute a uniform summary of benefits and coverage to new plan participants.  If there are any material changes to a plan that are not covered in the most recent summary, participants must be provided with 60 days notice of any such changes.
  • Patient-Centered Outcomes Research Trust Fund Fee – An annual fee of $2 ($1 for plan years ending during 2013) multiplied by the average number of covered lives under a health plan will be assessed to finance a government fund related to comparative clinical effectiveness. This fee specifically applies to both insured (fee is paid by insurer) and self insured (fee is paid by the plan sponsor – usually the employer) plans.

Non-grandfathered Plans Only

  • Quality of Care Reports – Non-grandfathered plans are required to make annual reports available to the public regarding performance measures related to improving quality of care. 

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