Plan Administrator's Alert #59

2011-09 Revised Rules About Required Preventive Care

You may have heard on the news or in your mail lately that health plans will now be required to cover contraception. Some of what we have heard is a little confusing and at times, contradictory, so this is a summary of what it means and how it applies to you.

One of the provisions of PPACA (the Patient Protection and Affordable Care Act) that was passed in March 2010 was that plans would be required to cover certain preventive services without cost sharing by the member. In the original interim regulations, the HHS (Department of Health and Human Services) directed the HRSA (Health Resources and Services Administration) to issue guidelines on preventive care specific to women’s health issues. The HRSA released those guidelines on August 1, 2011. A copy of the guidelines that were released on the HHS website (that we changed slightly to make more readable) is attached to this Alert. The guide explains the new covered services pretty well.

Since the new preventive services were adopted on August 1, 2011, all non-grandfathered plans must start covering these services with no member cost sharing for in-network providers no later than in the plan year that begins on or after August 1, 2012. For the vast majority of our self-funded health plan clients, that means the next time the plan renews its administrative services agreement on or after August 1, 2012. All plans may choose to cover these services before that date, rather than wait, if that makes financial and/or administrative sense.

The HRSA also included an exception to the required coverage for contraception for church plans. The applicable definition of a church plan is included in the footnote under the chart in the attached guidelines. Church plans will still be required to cover other preventive services.

If you have any question about this latest development in health care news, please feel free to call your ACS consultant, Lisa Scalzo, at extension 1003; Rich Harper at extension 1701, or Doug Lemmerman at extension 1100.