Federal authorities implementing the health reform law issued several pieces of important guidance late last week, excusing the individual mandate for part of 2014 for individuals offered coverage under non-calendar year employer plans, and finalizing rules regarding “minimum essential coverage” and the controversial contraception benefit mandate.
- Coverage under a non-calendar year employer plan. If an individual is offered at least minimum essential coverage under a non-calendar year employer health plan whose plan year begins in 2013 and ends in 2014, the individual is excused from the individual mandate through the last day of the 2013-14 plan year.
- Minimum essential coverage and the individual mandate. In final regulations, federal authorities imposed no additional requirements on employer-supplied minimum essential coverage (MEC). Thus, it appears that some bare-bones coverage will indeed constitute MEC, opening up additional planning opportunities for some employers.
- Contraception benefit mandate. In final regulations, the Administration offers wiggle room to quasi-religious nonprofit groups that hold themselves out as religious organizations and oppose (on religious grounds) providing contraception benefits under a health plan.
Edward Fensholt, J.D.
Health Reform Advisory Practice
Lockton Companies, LLC