Small Group Market may avoid full-scale health care reform changes until 2016

Under the Affordable Care Act (ACA) the definition of a small group will become 1-100 employees beginning on Jan. 1, 2014. However, states have been given the option to define small groups as 1-50 employees until 2016. Both Iowa and South Dakota define small groups as 1-50. This means that groups with 51-100 employees whether grandfathered or non-grandfathered will be considered large groups and therefore not be subject to small group ACA provisions and mandates and can keep their current group plan until 2016. Primarily, this affects the adoption of mandated essential health benefits and rating provisions under ACA.


This does not mean that groups of 51-100 are exempt from all ACA provisions and mandates. The following list of provisions, which should not be interpreted as a complete list, does apply to large groups (51+) and employers should invest the time to become knowledgeable about:

  • Dependent Coverage to Age 26
  • Pre-existing Conditions Limitations
  • Prohibition on Waiting Periods that Exceed 90 days
  • Summary of Benefits and Coverage Documents (SBC)
  • FSA Medical Limits
  • Employer Shared Responsibility
  • Mandatory Coverage for Clinical Trials


Impacts under small group provisions


In 2016, when the definition of a small group changes to 1-100, employers will be required to adopt new plans that comply with ACA regulations in accordance with small group provisions. Wellmark will offer groups with 51 to 100 employees several new products that are ACA compliant and will work with employers to provide options that best suit the needs of employers and their employees.


Wellmark is here to inform, lead, assist and support you through all the ACA changes. For more information, call your Wellmark representative, agent or broker about Wellmark coverage options that best meet the ongoing needs of you and your employees. Continue to monitor for updates.


Wellmark is not providing any legal advice with regard to compliance with the requirements of the Affordable Care Act (ACA) or the Mental Health Parity Addiction Equity Act (MHPAEA). Regulations and guidance on specific provisions of the ACA and MHPAEA have been and will continue to be provided by the U.S. Department of Health and Human Services (HHS) and/or other agencies. The information provided reflects Wellmark's understanding of the most current information and is subject to change without further notice. Please note that plan benefits, rates, renewal rate adjustments, and rating impact calculations are subject to change and may be revised during a plan's rating period based on guidance and regulations issued by HHS or other agencies. Wellmark makes no representation as to the impact of plan changes on a plan's grandfathered status or interpretation or implementation of any other provisions of ACA. Any questions about Wellmark's approach to the ACA of MHPAEA may be referred to your Wellmark account representative. Wellmark will not determine whether coverage is discriminatory or otherwise in violation of Internal Revenue Code Section 105(h). Wellmark also will not provide any testing for compliance with Internal Revenue Code Section 105(h). Wellmark will not be held liable for any penalties or other losses resulting from any employer offering coverage in violation of section 105(h). Wellmark will not determine whether any change in an Employer Administered Funding Arrangement affects a health plan's grandfathered health plan status under ACA or otherwise complies with ACA. Wellmark will not be held liable for any penalties or other losses resulting from any Employer Administered Funding Arrangement. For purposes of this paragraph, an "Employer Administered Funding Arrangement" is an arrangement administered by an employer in which the employer contributes toward the member's share of benefit costs (such as the member's deductible, coinsurance, or copayments) in the absence of which the member would be financially responsible. An Employer Administered Funding Arrangement does not include the employer's contribution to health insurance premiums or rates.


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Wellmark Blue Cross and Blue Shield is an Independent Licensee of the Blue Cross and Blue Shield Association doing business in Iowa and South Dakota.
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