There will be many changes required to health or cafeteria plan documents in 2014 as a result of the Patient Protection and Affordable Care Act (PPACA), and few, if any of these changes, have been inserted in these documents.
Listed below are these changes:
- New Adult Dependent definition extending coverage to age 26
- Coverage of preventive services
- No lifetime or annual limits
- Expanded ERISA claims and appeals procedures
- $2,500 cap on employee contributions to health flexible spending accounts (FSAs)
- Expanded change of status rules
- Possible health FSA $500 carryover provisions
- Ending pre-existing condition exclusions
- 90-day maximum waiting periods for health benefits
Regulators provided generous transition and documentation rules — which run out at the end of 2014.
Plans also should be reviewed (and likely changed) to address last year’s Supreme Court decision regarding the Defense of Marriage Act.
Final Shared Responsibility regulations also will require that critical “Pay or Play” decisions be addressed and documented.
As a result of all of the above, plan documentation tasks for 2014 should be under way. In most cases, the health insurance carrier will address this but, if necessary, the Manufacturer & Business Association will be in a position to help you to be compliant.