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December 15, 2010 at 07:00 PM
The HHS’ decision to curb the implementation of certain new mini-med plans has changed this marketplace slightly since the writing of this article. Look for coverage in upcoming weeks about how this move may affect your practice, and the limited benefit industry as a whole.
You’ve heard the saying: “The more things change, the more they stay the same.” This is certainly where things stand right now with the limited medical marketplace. The much ballyhooed date of Sept. 23 came and went with nary a change on the limited medical plan landscape.
If you’ll remember, Sept. 23 was the six month anniversary of the passage of PPACA. It was on this date that grandfathered plans would be required to meet certain provisions of PPACA in order to maintain grandfathered status as a health plan. Earlier this year, it appeared that grandfathering rules would strongly affect the limited medical (also known as mini-medical or mini-med) marketplace by requiring certain plans, among other things, to cover dependants to age 26, remove pre-existing condition limitations, and remove annual and lifetime limits.
The removal of annual limits (or meeting at least $750,000 in 2011) threatened to end the existence of any limited medical plan that was filed as a group health plan and included co-insurance features. Supposedly, this would have meant that beginning on Oct. 1, 2010, any plan renewing with these features would need to be replaced, therefore affecting a majority of the lives covered on limited medical plans today.
Mini-med plans saved?
After a feverish lobbying effort by the carriers most affected by PPACA, the Department of Health and Human Services (HHS) saw fit to offer a waiver process by which carriers, plan administrators, or employers could request exclusion from the annual limit rule. Early feedback indicates that the HHS has granted most, if not all, of the waivers. The minimum loss ratios are also a contentious point for limited medical plans, and early signs indicate that the government might waive that restriction, as well.
