Effective Date of Health Care Reform

[Guest Ira Hayes]

Facts:

1. Group health plan fully insured on March 23, 2010

2. Contract renews April 1, 2010

3. Plan year begins December 1, 2010

4. Contract renews April 1, 2011

Query:

On what date must group health plan remove all lifetime dollar limits and unrestricted annual limits on essential benefits as well as remove pre-existing condition limitations on covered individuals under age 19 and allow all children of covered employees not eligible for other employer sponsored group health plan coverage to join and remain on coverage until 26th birthdays?

[GMK]

December 1, 2010, gets my vote. Plan or policy year beginning on or after ...

[Guest Benefits Broker CO]

I would also suggest checking with the carrier. If the insurance contract year is April 1, the carrier may say that the changes don't need to be made until April, 2011.

[Guest PatriciaT]

Question re: effective dates, but re: automatic enrollment in health coverage: what is the concensus (if any) for the true effective date for this provision? I see that there is no separate effective date, and that has been interpreted to mean the law's enactment date is the effective date. But then I look to the text of the new provision, and it starts: "in accordance with regulations", which have not been issued, so I have heard some suggest that the issuance of regulations is the actual (or at least the earliest) effective date. Fianlly, I have seen this section's implementation coupled with the next following section of the law that requires notice to employees regarding coverage - that effective date is in 2013.

I know which option I totally do not want as the effective date, but has anyone dealt with this yet? Thanks in advance.