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Consolidated and Further Continuing Appropriations Act, which became law in December 2014, Congress exempted health plans designed to cover expatriates from most of the requirements of the Affordable Care Act (ACA). The exemption will generally apply where a group health plan provides significant health coverage and substantially all of the covered employees fall under any of the following categories:
Although the exemption is extensive, expatriate plans must continue to meet certain ACA requirements. For example:
By its terms, the new exemption applies only to health plans issued or renewed on or after July 1, 2015. However, for many expatriate plans, there are currently exemptions in place for
market reforms and
certain fees and
assessments required under the ACA.
Edward I. Leeds is counsel at
Ballard Spahr LLP, where he concentrates on issues relating to the design, administration, and taxation of health and other welfare benefits plans.
© 2015 by Ballard Spahr LLP. All rights reserved. Reprinted with permission.
Related External Article:
Appropriations Deal Addresses Expatriate Health Plans, Towers Watson, January 2015
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