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As work continues at a rapid pace among negotiators on merging different versions of healthcare reform legislation, the groups said that a longer transition period is needed because both the House and Senate bills include a number of provisions that will require employers and health plans to take significant action to achieve compliance.
These will include making policy and contract revisions, information technology system upgrades, modifications to employee benefit and marketing materials, and development of employee and customer communications.
In a letter to Congressional leaders, the groups also emphasize that many provisions of the proposal would require new regulations, state law changes and approval from state insurance departments.
The letter was signed by officials of the American Benefits Council; America's Health Insurance Plans; Blue Cross Blue Shield Association; the ERISA Industry Committee; the Healthcare Leadership Council; the National Association of Health Underwriters; the National Association of Manufacturers; the National Business Group on Health; the National Retail Federation; National Small Business Association; and the U.S. Chamber of Commerce.
To allow sufficient time to make changes necessary for compliance, these provisions should ideally be effective for plan years beginning 12 months after final regulations have been promulgated, the letter stated.
“At a minimum, the effective dates should be no sooner than plan years beginning 12 months after enactment of the legislation, with a safe harbor for plan sponsors and health plans that have acted in good faith compliance with the new law,” the letter said.
A similar approach has been used with implementation of other major federal health legislation, including, HIPAA privacy and mental health parity requirements, the letter noted.
The letter was sent to the Democratic leadership of the House and Senate as Congress prepares for the final push in reconciling far-differing versions of healthcare form legislation.