We closed the first quarter of 2010 with the passage of the most sweeping and comprehensive piece of legislation impacting employer-sponsored health plans since the enactment of ERISA. While the Patient Protection and Affordable Care Act (as amended by the Health Care and Education Reconciliation Act) will take several years to fully implement, there are many provisions that are effective for health plans as early as October 1, 2010. One of the greatest challenges facing employers today is how to implement these provisions in the wake of many unanswered questions and the absence of guidance from federal agencies regarding a multitude of issues.
The Health and Welfare Team at Kilpatrick Stockton provided a basic framework within which to understand this new legislation and outlined a compliance plan to guide employers through these unchartered waters, with a particular focus on key decisions and plan changes that need to be made for 2011. The team also discussed several other developments in the health and welfare plan area that must be considered as part of planning for 2011, including:
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