Private Exchanges under the ACA

[Guest hb95]

Is anyone aware of any official guidance on requirements or restrictions relating to private entities establishing "exchanges" or "marketplaces" for individuals to purchase health coverage that satisfies the ACA?

[Chaz]

Briefly, to the extent that the program is set up so that employees are given X dollars to purchase individual policies on a private exchange, it probably won't work but if you are asking about the Aon, Mercer, etc. private exchange, it is my understanding that these programs are just permitting employees to choose among a number of different group policies so it might work.

There are some (generally, the parties who are selling the arrangements) who say that the DOL did NOT put the kibosh on employers providing a defined contribution amount for employees to purchase individual policies, so there is some uncertainty but, in the absence of more guidance, that is certainly an aggressive approach.

There is no "official" guidance that I am aware on the issue. The DOL put out a FAQ on the effect of PPACA's restrictions on annual and lifetime limits on standalone HRAs, which is the only guidance that I have seen.

[GBurns]

There is so much information available that my suggestion is to jut use Google and read until you are satisfied. You also need to search the HHS website for summaries etc because the final rules are in this 644 page document https://s3.amazonaws.com/public-inspection.federalregister.gov/2012-06125.pdf