Introduction
On February 25, 2019 the Department of Labor, Department of
Health and Human Services, Treasury Department and the Internal
Revenue Service (the "Departments") published a request for information (the
"ROI") on grandfathered plans, signaling that a
relaxation of the grandfathering rules may be forthcoming. This
post gives a brief history of grandfathered plans and describes the
information requested in the ROI (for which responses are due March
27, 2019).
History of Grandfathered Plans
The Affordable Care Act (ACA) created a large array of new rules
for health plans. By now, many of these rules, such as the required
coverage of children up to age 26 and the prohibition of
pre-existing condition limitations, are familiar to most
Americans.
