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When is a multi-employer, collectively bargained, health and welfare fund required to comply with the requirement to cover dependents up to age 26? I know for most plans, it is the first plan year beginning after September 23, 2010. However, there is a provision in PPACA that appears to extend the effective date to the date of termination of the last collective bargaining agreement. There is also a question of whether or not that provision even applies to self-funded plans.

What are others thinking?

Posted
When is a multi-employer, collectively bargained, health and welfare fund required to comply with the requirement to cover dependents up to age 26? I know for most plans, it is the first plan year beginning after September 23, 2010. However, there is a provision in PPACA that appears to extend the effective date to the date of termination of the last collective bargaining agreement. There is also a question of whether or not that provision even applies to self-funded plans.

What are others thinking?

We contacted HHS last week and were told that within two weeks they will issue advice on this very confusing issue.

  • 4 months later...

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