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The Employee Benefits Security Administration, an arm of the U.S. Department of Labor, has published notice guidance that can be used to meet the requirements today in the Federal Register.
Employers can use the guidance when informing employees about the possibility that they might be eligible for premium assistance through Medicaid or through the Children’s Health Insurance Program.
Congress included Medicaid and CHIP notice requirements in the Children’s Health Insurance Program Reauthorization Act of 2009, a health care reform bill that President Obama signed Feb. 4, 2009.
The law required employers to begin providing notices last spring, but the law did not require EBSA to publish a model notice until a year after the law was signed.
Officials at EBSA and the U.S. Department of Health and Human Services suggested in early 2009 that employers and benefits advisors should try talking to state regulators about how to tell employees about coverage options, but it is not clear that all states succeeded at communicating with employers and benefits advisors about notice procedures.
Employers and others hungry for notice details made search terms related to “CHIP notice requirements” some of the most popular National Underwriter Life & Health search terms throughout much of 2009.
EBSA now has posted a model notice at http://www.dol.gov/ebsa, officials say.
To implement the premium assistance notice requirements, EBSA has developed a list of states that offer programs that should be promoted through the notices.
“If a group health plan provides benefits for medical care directly (such as through a health maintenance organization); or through insurance, reimbursement or otherwise to participants, beneficiaries, or providers in one of these States, the plan is required to provide the Employer CHIP Notice, regardless of the employer’s location or principal place of business (or the location or principal place of business of the group health plan, its administrator, its insurer, or any other service provider affiliated with the employer or the plan),” EBSA officials say in the discussion of the notice requirements that appears in the Federal Register.
Officials note tht the effective date of the notice requirements is now "the first day of the first plan year after February 4, 2010; or May 1, 2010."
EBSA officials also discuss the form and content of the notice, and the timing and delivery of the notice, and they ask for public comments. Comments are due April 5.
A copy of the Federal Register notice is available here.
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CLARIFICATION: In an earlier version of this article, the effective date given for the notice requirements was in early 2009. EBSA now has pushed the effective date back to May 1 for many plans, and to a date between Feb. 4 and May 1 for plans that start their next plan year during that period.