ACA Final Regulations on Grandfathered Plans, Preexisting Condition Exclusions, Lifetime and Annual Limits, and Other Matters

The U.S. Departments of Health and Human Services, Labor, and the Treasury jointly issued final regulations on November 18, 2015, addressing a variety of topics under the Affordable Care Act (?Ç£ACA?Ç¥), including, (1) the preservation of grandfathered plan status, (2) the prohibition on preexisting condition exclusions, (3) the prohibition on lifetime and annual dollar limits for essential health benefits, (4) the prohibition on rescissions of coverage, (5) the extension of certain dependent child coverage to age 26, (6) internal claims and appeals and external review rules, and (7) certain patient protection rules (including rules regarding the designation of a primary care physician and coverage for emergency services). These final regulations primarily combine previously issued proposed and interim final regulations, posted ACA FAQs, technical notices and other informal guidance for each of these topics with relatively few noteworthy changes for employer-provided group health plans. The final regulations will generally be effective for plan years beginning on or after January 1, 2017. Until then, the prior existing guidance remains in effect. The final regulations?áare available?áhere.