At Sterling Benefits, we are proactively working with multiple resources to dissect the various facets of the law and to understand the guidelines and timelines it presents to our clients. You can expect that we will provide ongoing communications and information as interpretation and implementation details continue to unfold from the government.

Our priority at Sterling Benefits is to stay focused on delivering value and quality customer service to our customers as we work together with health care reform. Significant changes will take place in 2014. In the meantime, there are some items that will require attention much sooner. We will keep you posted as details and clarifications from the government are made available. We encourage you to review this information and utilize our office as a resource in addressing questions and concerns.

Tuesday, March 19, 2013

Most PPACA Provisions for Expatriate Plans Delayed Until 2015

On March 8, 2013, the Departments of Labor, Health and Human Services and Treasury issued a Frequently Asked Question (FAQ) announcing that compliance with most Patient Protection and Affordable Care Act (PPACA) provisions is being delayed for expatriate plans meeting this definition:
  • Insured group health plans with plan years ending on or before December 31, 2015, in which enrollment is limited to individuals residing outside of their home country for at least six months of the plan year and any covered dependents. 
This delay impacts most PPACA provisions, including the prohibition on discrimination in favor of
highly compensated individuals, the Summary of Benefits and Coverage, and guaranteed renewal of expatriate coverage even when an individual is no longer an expatriate.

There are a few areas for which we expect there will be additional guidance or clarification.

Read the FAQ.