Final ACA Guidance Wellness Plan Rules Cadillac Changes | Mercer US

Final ACA Guidance Wellness Plan Rules Cadillac Changes

Our Thinking / Healthcare /

Final ACA Guidance Wellness Plan Rules Cadillac Changes
Calendar17 November 2015

Final ACA rules settle the standards for grandfathered plans, pre-existing condition exclusions, lifetime and annual limits, rescissions, adult child coverage, appeals, and patient protections. The tri-agency rules finalize various interim and temporary regulations "without substantial change." Most revisions from the earlier rules incorporate clarifications issued in informal guidance like FAQs. The final rules apply for plan years starting after Dec. 31, 2016.

Proposed Equal Employment Opportunity Commission (EEOC) rules clarify that an employer can in some cases offer limited incentives for spouses covered by its group health plan to complete health risk assessments that ask about health status without violating the Genetic Information Nondiscrimination Act. Offering inducements for information about an employee's children, however, would violate the Act.

The Obama administration is willing to consider changes to the ACA’s “Cadillac tax” on high-cost health plans, White House Press Secretary Josh Earnest said last week during a briefing for reporters. Employers and organizations urging Congress to scrap the tax welcomed the news but made clear that only full repeal is acceptable to them. On Capitol Hill, there is growing talk of attaching language to repeal or modify the tax to a year-end tax “extenders” bill. Whether that will happen is highly uncertain, however, given what promises to be a contentious debate over whether/how the resulting loss of revenue should be paid for.

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