Thomas Greene is a Partner in our
Boston office.
The Government Agencies Overseeing Enforcement of the
ACA Have Provided Relief for Employers Offering Certain
Plans
HIGHLIGHTS:
- IRS, DOL and HHS finalize guidance on "excepted
benefits" requirements for dental, vision, long-term care and
employee assistance programs.
- Employers need to review their plans to either confirm the
benefits are excepted, or that their programs comply with the
requirements of the ACA.
The Patient Protection and Affordable Care Act (ACA) imposes
numerous requirements on health plans, including group plans
maintained by employer sponsors. An enhanced claims process,
coverage for dependent children until age 26 and a prohibition on
annual and lifetime dollar limits are just a few. Because dental,
vision, and long-term care benefits and employee assistance
programs are typically limited in nature, without an exception to
the ACA requirements, these programs could violate ACA and
