New Extended "Grace Period" for Health Care Reform Mandates

In this article, Garrett Fenton discusses the U.S. Department of Labor’s extended grace period for certain requirements imposed upon employer-sponsored health plans under the Patient Protection and Affordable Care Act (PPACA). This extended grace period came as a response to numerous comments from employers, trade associations, and other interested parties, expressing serious concerns about the ability of employers (or their insurers, if applicable) to implement the newly-required procedures before PPACA’s deadline.

The U.S. Departments of Health and Humans Services, Labor, and Treasury had previously pledged not to enforce these provisions, until July 1, 2011, against an employer (or insurer) that was at least “working in good faith” to implement them. Recent guidance put forth by the DOL announced an extension and modification of this grace period, until January 1, 2012 (for most plans), to “act as a bridge” until the agencies have a chance to amend the federal regulations implementing these requirements.
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