Unless you have been living under a rock, you are no doubt aware that the long-debated Healthcare Reform Bill was passed by Congress and signed by the President this week.  It is, to say the least, a complicated piece of legislation.  Like many of  you, I have been trying to figure out what impact the new rules and regulations will have on ALM and on us as individuals. 

For the past dozen years we have utilized the services of a team of consultants at PricewaterhouseCoopers to help us navigate our way through the health insurance maze.  I asked the partner we work with there, Aron Minken, to give me PWC's early analysis of how the Healthcare Reform bill will impact us.  In the short-run (meaning 2010) it looks like there will be no changes.  But in future years we will need to revise our plans to conform to the new rules. 

Depending on your personal situation, some of these changes could be very positive.  But the great unknown is how these changes will impact our costs -- both in terms of the premiums we pay for our insurance and the out-of-pocket costs for revisions to our coverage.

Here's what Aron and PWC had to say:

"This legislation is quite complex, and there are a number of provisions that are likely to impact ALM and its employees.  We don't believe that any changes to the medical plans are needed for 2010.  There are, however, a number of plan design and process changes that will need to take place in 2011 and beyond.  

Major changes will include the requirement that large employers (over 200 employees) automatically enroll new full-time employees in one of their health benefit plans and continue the enrollment of current employees in a health plan (we understand that employees may, however, opt out of such coverage).  Also, by March 1, 2013, all employers will be required to provide notices to current employees, and to new employees at the date of hire, informing the employees of the existence of a State Healthcare Benefits Exchange and other specifics regarding eligibility for benefits in the Exchange, which will be providing healthcare coverage effective January 1, 2014.

A summary of some of the other major provisions affecting large employers is as follows:

1. Plans must offer coverage for the children of covered individuals through the end of the plan year during which they attain age 26.  For plan years before 2014 for existing plans, this provision does not apply to children who are eligible to enroll in another employer-sponsored plan.

2. Plans may not place lifetime limits on the dollar value of coverage.

3. Beginning in 2014, plans may not impose any annual limits on coverage; prior to 2014, only "reasonable" annual limits, as determined by the Secretary of Health and Human Services, may be imposed.

4. Plans may not have waiting periods longer than 90 days, effective in 2014

5. Plans must eliminate pre-existing condition exclusions, effective for children in the first plan year beginning six months after enactment (September 23, 2010); effective for adults in 2014.

6. Plans may not rescind coverage except in the case of fraud.

7. Effective in 2014, out-of-pocket limits may be no greater than the current year's HSA out-of-pocket maximum (e.g., the 2010 amounts are: $5,950 per individual, $11,900 per family, and these amounts will be indexed).

8. Employer plans must have an HHS-approved binding external review process

9. Employers will be required to report the aggregate value of health benefits on employees' W-2 beginning in 2011.

10. Changes to flexible spending accounts (FSAs):

a.  The cost of over-the-counter drugs not prescribed by a doctor may not be reimbursed through an HRA or health FSA after January 1, 2011

b.  Increased penalty for nonqualified HSA or Archer MSA purchases or distributions will increase from 10% to 20%, effective for distributions in 2011

c.  The reconciliation bill would limit the maximum contribution to an FSA to $2,500 annually, beginning in 2013".

Our benefits team will be meeting with Aron to get more information, and will pass that along to us.  These are obviously big changes and it may take some time for us to fully understand all the implementation issues and the cost impact.