Are your health plans compliant with the Affordable Care Act (ACA)? If you are a small employer that has put off making the switch and have kept your non-compliant plans under “transition relief,” also known as “Grandmothering,” this grace period has come to an end and your next renewal will be onto an ACA compliant plan.
The Colorado Division of Insurance (DOI) announced on March 13th, 2015 that Individual and Small Group plans not considered to be ACA-compliant will not be allowed to continue into 2016. Insurance companies will no longer offer non-compliant plans during your 2015 renewal, and you’ll need to choose new plans that are ACA-compliant. The only exception is if you have grandfathered plans and are not yet subject to this provision of the Affordable Care Act.
Fall River will be reaching out to all of our small group clients with Grandmothered plans to help them convert to ACA-compliant plans by the end of 2015.
More History. In March 2014, President Obama announced the transition relief provision that allowed the states to choose whether to allow the continuation of non-compliant plans for two more years. In May of 2014, Colorado chose to allow non-compliant plans in late 2014, into 2015, to allow individuals and small groups more time to prepare for the transition. At the time the Insurance Commissioner, Marguerite Salazar, felt that employers, carriers, and consumers would benefit from having additional time to prepare for the new ACA plan requirements. However this year she stated that in her opinion all involved have had time to get ready and that it was time to implement the ACA-compliant plans. The recent decision does impact a few hundred thousand people in Colorado that are in either insured under Individual or Small Group plans that are not yet ACA-compliant.
What happens next? Insurance carriers will notify the individuals and small employers covered under non-compliant plans of their discontinuation in 2015. The notice of termination should be provided at least 90 days before the termination of the plan. Companies will be provided with information about alternate ACA-compliant plans for consideration upon renewal. For Individuals losing their non-compliant plan, the loss of their existing coverage is considered a qualifying event to take advantage of the special enrollment period to select new coverage on the Exchange or directly through the carrier.
Small Business Renewal Dates. Many small companies (2-50 employees) moved their renewal date to the very end of the year to delay the impact of the ACA-compliant plans as long as possible. However, so many renewals are now in the last quarter of the year that it’s hard to get the carriers’ attention. If your business ideally does not want to have a renewal date in November or December, you may wish to consider moving your renewal date in 2015 or 2016, if your carrier allows it. We can help you evaluate whether this would be the right strategy for us – just This email address is being protected from spambots. You need JavaScript enabled to view it. or give us a call!
