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Grandfathered status is not lost as a result of:
- Enrolling new employees of family members
- Changes to premiums
- Changes to comply with federal or state requirements
- Voluntary compliance with health reform mandates
- Changes to third-party administrators
- Changing from a health reimbursement arrangement to major medical coverage
- Changing from fully-insured to self-funded
- Changing the plan's provider network
- Changing the plan's prescription drug formulary
Grandfathered status may be lost as result of:
- Elimination of all or substantially all benefits to diagnose or treat a particular condition
- Increasing any co-insurance percentage
- Significantly increasing any co-payments
- Significantly increasing any deductible or out-of-pocket limit
- Significantly lowering employer contributions
- Adding or lowering annual limits on benefits
- Changing insurance carriers
**There are also procedural requirements for maintaining grandfathered plan status:
- Status is determined separately for each benefit option available uder the plan
- Documentation must be maintained of the plan terms in effect on March 23,2010 and all changes after March 23, 2010 to demonstrate compliance
- Must disclose grandfathered status in plan materials and provide contact information for questions
Groups should seek legal counsel to determine their specific obligations under the health Care Reform law.
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