Health Care Reform Alert: PCOR Fee Reminder and Recently Issued FAQs

The Department of Labor (DOL), Health & Human Services (HHS) and Internal Revenue Service (IRS) recently released two additional sets of Frequently Asked Questions on the Affordable Care Act, both regarding non-grandfathered group health plans, summarized here:

  • Guidance Issued on Coverage for Preventive Items and Services – Issued May 12, 2015, FAQ 26 discusses the ACA requirement for a non-grandfathered group health plan to provide coverage for in-network preventive items and services (including contraception) without any cost-sharing requirements.
  • FAQs Further Clarify New Embedded Out-of-Pocket Requirement – Issued May 26, 2015, FAQ 27 further clarifies the new embedded out-of-pocket rule for non-grandfathered plans. The FAQ confirms that this rule applies to all non-grandfathered group health plans, including self-insured plans, large group health plans and high deductible health plans.

Finally, this is a PCOR Fee Filing Reminder for Self-Insured Plans. July 31, 2015 is the deadline to file and pay the Patient-Centered Outcomes Research (PCOR) fee for self-insured plans, including Health Reimbursement Accounts. Also included is a summary of recent IRS FAQs that address how the PCOR fee works with a self-insured health plan on a short plan year.

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