And HR managers will be dealing with it all the way along. This article will serve as a checklist or reminder of all the areas in which you might need to evaluate and change your policies and procedures.

Aitken's advice came during the Society for Human Resource Management's (SHRM) recent annual Conference and Exposition in San Diego. Aitken is SHRM's director, government affairs.

What Are Employers Doing About PPACA?

Aitken started by sharing the results of a brief survey on employer reactions to the passage of PPACA.

Is your organization engaging in an analysis to determine the impact of the new health care reform law on your health care plan?

Will your organization pass on to employees any increased or decreased health care coverage costs (e.g., premiums, co-pays) in 2011 that may be directly or indirectly related to the new health care reform law?

In addition, 34 percent of responding organizations said they were considering alternative health care plans (e.g., less expensive coverage plans, health savings accounts, self-funding) as a result of the new health care reform law.

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Insurance Market Reforms

Market reforms include:

• Guaranteed issue and no health-status rating or pre-existing condition provisions for individual and small group health plans.
• Premiums to vary only by age, geography, family size, and tobacco use.
• Requirement for insured and self-insured healthcare plans to provide dependent coverage for married or unmarried children up to age 26.
• Requirement for health plans to provide first dollar coverage for preventive health services beginning in 2011 (unless grandfathered).
• Plans prohibited from establishing lifetime limits on the dollar value of benefits 6 months after enactment; and prohibited from establishing annual limits beginning in 2014.
• In 2014, states are required to create Health Insurance Exchanges where individuals and small employers can purchase health insurance.

What Employers Should Do Now

Here's what Aitken suggests employers do now:

• Brief senior leadership and employees on the new law and potential impact on organizations’ health plan(s)
• Communicate plan design changes before and during 2011 open enrollment
• "Model" potential implications of changes on plans
• Update Summary Plan Documents (SPDs)
• Provide new and existing employees with information about the exchanges (eligibility if employer coverage is unaffordable, free choice voucher, tax credits) beginning in 2013

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Additional Employer Responsibilities

Aitken points out the following additional concerns for employers:

• Beginning in 2014, penalties are assessed if the employer does not offer health coverage at all, if the employee is offered coverage that is "unaffordable," or if the plan has an actuarial value of less than 60 percent.
• Beginning in 2011, employers will be required to report the value of employees’ health benefits on W-2 forms.
• By March 2012, employers must provide a four-page, uniform summary of benefits for all plans (The Department of Health and Human Services is to provide a model summary.).
• Beginning in 2014, there can be no waiting periods over 90 days.
• Employers with more than 200 employees must automatically enroll new full-time employees in healthcare coverage, allowing for employee opt-out, likely effective in 2014.

In tomorrow's Advisor, more on PPACA, including whether or not you'll pay a penalty, and an introduction to a unique policy development program.

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