Hunton Employment & Labor Perspectives

The government has continued to issue a number of regulations and other guidance on the Patient Protection and Affordable Care Act (PPACA) and related health care laws, including the following:

• Final regulations on the use of “bona fide orientation periods” in coordination with waiting periods for health care coverage;
• IRS forms and instructions regarding reporting of health care coverage by health plans and large employers;
• Updated proposed rules on the required Summary of Benefits and Coverage;
• Guidance regarding use of “skinny plans”; and
• Preliminary guidance on the “Cadillac” tax on high-cost health plans.

We have developed a compliance reference tool to assist employers in developing a better understanding of what is required under PPACA and the required timeframe for any applicable changes. This tool contains a timeline/checklist, along with an appendix providing additional information on many of the requirements (which are linked to the timeline/checklist for easy access). See the most recent version, which has been updated as of the beginning of April 2015.