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Affordable Care Act Implementation Frequently Asked Questions

  • Part I — This set of FAQs addresses implementation topics including compliance, grandfathered health plans, claims, internal appeals and external review, dependent coverage of children, out-of-network emergency services, and highly compensated employees.
  • Part II — This set of FAQs addresses grandfathered health plans, dental and vision benefits, rescissions, preventive health services, and ACA effective date for individual health insurance policies.
  • Part III — This set of FAQs addresses the exemption for group health plans with less than two current employees.
  • Part IV — This set of FAQs addresses grandfathered health plans.
  • Part V — This set of FAQs addresses a variety of ACA implementation topics, the HIPAA nondiscrimination and wellness program rules, and the Mental Health Parity and Addiction Equity Act of 2008.
  • Part VI — This set of FAQs addresses grandfathered health plans.
  • Part VII — This set of FAQs addresses the Summary of Benefits and Coverage and Uniform Glossary requirements of PHS Act §2715 and the Mental Health Parity and Addiction Equity Act of 2008.
  • Part VIII* — This set of FAQs addresses the Summary of Benefits and Coverage requirements of PHS Act §2715.
  • Part IX* — This set of FAQs addresses the Summary of Benefits and Coverage requirements of PHS Act §2715.
  • Part X* — This FAQ addresses the Summary of Benefits and Coverage requirements of PHS Act §2715.
  • Part XI — This set of FAQs addresses the employer notice of coverage options, health reimbursement arrangements, disclosure of information related to firearms, employer group waiver plans supplementing Medicare Part D, fixed indemnity insurance and payment of PCORI fees. Related information: CMS Bulletin on Non-Medicare Supplemental Drug Benefits.
    (**Note: See Technical Release 2013-03 for comprehensive guidance addressing health reimbursement arrangements that was issued after the date of these FAQs.)
  • Part XII — This set of FAQs addresses limitations on cost-sharing under the ACA.
  • Part XIII — This set of FAQs addresses expatriate health plans.
  • Part XIV* — This set of FAQs addresses the Summary of Benefits and Coverage requirements of PHS Act §2715.
  • Part XV — This set of FAQs addresses annual limit waiver expiration date based on a change to a plan or policy year, provider non-discrimination, coverage for individuals participating in approved clinical trials and transparency reporting.
  • Part XVI — This set of FAQs addresses the employer notice of coverage options and the 90-day waiting period limitation.
  • Part XVII — This set of FAQs addresses the implementation of the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA), as amended by the Affordable Care Act.
  • Part XVIII — This set of FAQs addresses coverage of preventive services, limitations on cost-sharing, expatriate health plans, wellness programs, fixed indemnity insurance, and the Mental Health Parity and Addiction Equity Act of 2008.
  • Part XIX — This set of FAQs addresses updated DOL model notices, limitations on cost-sharing, coverage of preventive services, health FSA carryover and excepted benefits, and the Summary of Benefits and Coverage requirements of PHS Act §2715.
  • Part XX — This set of FAQs addresses coverage of preventive services.
  • Part XXI — This set of FAQs addresses limitations on cost-sharing under the ACA.

* Note:

  • Some of the guidance in FAQs Parts VIII, IX, and X has been superseded by guidance contained in FAQs Part XIV.
  • Some of the guidance in FAQs Parts VIII, IX, X, and XIV has been superseded by guidance contained in FAQs Part XIX.