Boca Benefits Consulting Group Inc.

HHS Releases Final Interim Guidance on “Grandfathering”

Today, the Departments of Health & Human Services, Labor, and Treasury issued long-awaited interim final regulations that specify how “grandfathered” status will be defined and maintained. Regulators spelled out which actions or changes will (and will not) cause a plan to lose its “grandfathered” status.

These interim final regulations will still require analysis by carriers, consultants and employers relative to their implications and effect on employer-sponsored healthplan change decisions. We expect substantial industry opinions in the next day or so. HR and benefits professionals should keep a close eye on these developments.

Please contact us via email if you have questions about the interim final regulations. BBCG will be receiving guidance from carriers, and their attorneys, which may be valuable to you.


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Two items about which employers need to be aware as they make healthplan policy decisions:

1. It appears unlikely that the COBRA subsidy will be re-implemented retroactively. There is serious opposition on the part of budget-conscious Democrats in Congress to extend the subsidy, making its passage problematic. At least for the time being, those going into a COBRA status need to be charged the full amount. In the unlikely event that the subsidy is retroactively implemented, COBRA participants can be reimbursed.

2. It is critical that employers keep up to date on rules that are about to be promulgated relative to what changes are allowable relative to retaining the “grandfathered” status of their existing employer-sponsored plans. Plan changes that add cost or reduce benefits to employees may cause a plan to loose its “grandfathered” status thus making it required to immediately abide by all PPACA provisions (i.e., as opposed to the 2014 statutory date). Information on these rules will likely be public shortly.


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If you are an employer or senior management person trying to keep up with the provisions of PPACA, you are likely very frustrated as are many others. It is a moving target with interpretations and interim rules emerging almost daily. I noted in today’s St. Pete Times comments made following a seminar hosted by the Tampa Chamber on the details of PPACA. Even the normally informed “experts” are a little behind the curve and major employers are struggling with decisions due to incomplete guidance.

CIGNA has been holding a series of web meetings hosted by both their own employees and outside experts. The last one had two attorneys who specialize in PPACA as presenters and who were excellent in terms of their level of knowledge and current information. Following the presentation, a web conference operator moderates individual telephone questions directly to the presenters for specific questions and answers.

You do not need to be a CIGNA client to take advantage of this resource. Even if you just “lurk” without asking any questions, you will be brought up to speed on many details that might not otherwise be available to you. BBCG encourages you to register via the below link and join the web meeting at 2 P.M. June 17, 2010.

Click here for the CIGNA registration web page and link to additional health reform information available from CIGNA.


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For those persons who prefer to do business with a long-established insurance carrier in the individual healthcare market, BBCG offers United Healthcare’s “UnitedHealthOne” (f/k/a Golden Rule) products. Various traditional, high deductible, point-of-service and HSA products are available. Please feel free to use this service to explore options that you feel might meet your needs.

Please click on the above Golden Rule icon to open the auto-quoting page. This is a free and non-binding service unless the user actually submits an application.

This service is in addition to the similar auto-quote function provided by BBCG via the CIGNA individual/small group market segment per our earlier blog entry at http://bocabenefits.com/blog/?p=588.

Both CIGNA and United Healthcare offer individual products as solutions to the “To Age 26” gap many college seniors may face while waiting for eligibility under one of their parent’s health plans.


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In addition to the UnitedHealthOne (f/k/a Golden Rule) individual products auto-quote function from United Healthcare , BBCG now has a similar auto-quote function available for CIGNA products. Just click on the CIGNA logo above to open the quoting window.

Like the UnitedHealthOne products, CIGNA products also address the “To Age 26” issue for graduating college seniors.

This is a free and non-binding process unless an application is actually submitted by the user. 


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Below is link to excellent National Association of Insurance Commissioners “Frequently Asked Questions” resource relative to the specfics of PPACA (i.e., 2010 health care reform statute). It is segmented by Consumers, Employers and Seniors.

Click here for link.

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CIGNA is hosting an educational teleconference on the subject of early implementation of the “To Age 26” provision of PPACA. Valuable for all employers sponsoring employee health plans (i.e., both insured and self-funded). Possibly broker and CIGNA client oriented. However, pertinent to all regardless of present carrier and/or TPA.

CIGNA teleconference registration link.

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Below are two links to resources provided by the U.S.  Department of Health and Human Services in regard to the new “To Age 26” provisions of PPACA. Important reading for graduating college seniors, parents and other adult children less than 26 years of age.

HHS Frequently Asked Questions

HHS fact sheet

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United Healthcare announced that it has agreed to the White House’s request to provide coverage for graduating college seniors under the “To Age 26” provision of PPACA (i.e.,  2010 health reform act). See below excerpt from announcement. Click here for full broker announcement.

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On April 19 we (sic) announced that we will work with customers that wish to extend the health coverage that graduating college students currently have under their parents’ plans. As a result, we are mailing letters beginning May 5 to all fully insured customers* regarding our graduate coverage initiative.  The mailing includes the Customer Notice, Letter and FAQ and Opt-Out form posted above.

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Following on CIGNA’s earlier announcement this week regarding early implementation of the PPACA “to age 26” provision, CIGNA has announced today that they will also implement early the “anti-rescission” provisions of PPACA prior to the statutory requirement of 9/23/2010. CIGNA has announced they will make the policy change effective 5/1/2010.

It would appear that CIGNA is attempting to capture the public relations high ground on these decisions relative to their healthcare insurance competitors. However, these are relatively easy changes to effect and will not substantially alter the competitive balance as other major carriers make similar decisions to implement certain PPACA provisions early.

Below Excerpt from CIGNA Press Release:

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CIGNA’s business practices are already compliant with the suggested reforms that are to be implemented on September 23, 2010. CIGNA is confirming that it will not rescind the coverage of any premium-paying customer except in cases of deliberate fraud or intentional misrepresentations of material facts. CIGNA will also institute a policy of third party review if a rescission is to be made.

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Click here for full press release.


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