TIME FOR YOUR ERISA GROUP HEALTH PLAN CHECK-UP!
In order to assist employers and other benefit administrators with the complex area of compliance with various regulations under Part 7 of ERISA, the DOL has compiled a check-list. The areas that are covered are:
- Limits on Preexisting Condition Exclusions
- Certificate of Creditable Coverage Provisions
- Special Enrollment Provisions
- HIPAA Nondiscrimination Provisions
- Wellness Program Provisions
- HMO Affiliation Period Provisions
- MEWA or Multiemployer Plan Guaranteed Renewability Provisions
- Mental Health Parity Act (MHPA) and Mental Health Parity and Addiction
- Equity Act (MHPAEA) Provisions
- Compliance with the Newborns’ and Mothers’ Health Protection Act (Newborns’ Act) Provisions
- Compliance with the Women’s Health and Cancer Right Act (WHCRA) Provisions
- Compliance with the Genetic Information Nondiscrimination Act (GINA) Provisions
- Compliance with Michelle’s Law
While some of these requirements may change as we get more regulations and clarifications under PPACA, until that is received Group Health Plans must still comply with the existing laws. In any event, this check list can be an invaluable tool that employers can use while they review their current health plans in preparation for the full implementation of the new Healthcare laws.
It also can’t hurt to keep this check list in your records to show a good faith effort of compliance with ERISA should your plan be audited. With new audit activity increasing, this simple tool can hopefully minimize the risk of having a problem with your Group Health plan(s).