Government Releases New FAQs on ACA Implementation

On May 2, 2014, the U.S. Department of Labor (DOL), Department of Health and Human Services (HHS) and Department of the Treasury released a set of Frequently Asked Questions (FAQs) about Affordable Care Act (ACA) implementation that addressed the following issues:

  • Updated Department of Labor Model Notices:  The FAQs provide guidance on the DOL’s updated model COBRA notices for single-employer plans to address the relationship between COBRA and the ACA. Because some individuals may find that coverage on the Marketplace/Exchange is more affordable than COBRA, the new notice explains there are other coverage options available besides COBRA.  
  • Limitations on Cost-Sharing under the ACA:  The FAQs provide guidance on out-of-pocket maximums as they relate to out-of-network providers, generic drugs, and reference-based pricing structures.
  • Coverage for Preventive Services:  The FAQs provide guidance on tobacco cessation interventions.
  • Health FSA Carryover and Excepted Benefits:  The FAQs provide guidance on the modified “use-or-lose” rule.
  • Summary of Benefits and Coverage:  The FAQs provide guidance on the updated SBC template and extension of specific safe harbors and other enforcement relief.

For more information about the ACA, please contact your Trust Fund counsel.

By Kristina Zinnen | May 6, 2014

Legal Developments