National Health Care Reform: The Keys to Maintaining Grandfathered Status (If Desired) and Upcoming Notice Obligations

October 1, 2010

The following is the latest in a series of Patterson Belknap Alerts regarding the implications of the recently enacted health care reform under the Patient Protection and Affordable Care Act and the Health Care and Education Reconciliation Act of 2010 (referred to collectively here as "PPACA") for employers. This Alert describes recent guidance regarding the types of changes to a group health plan which will cause the plan to lose its "grandfathered" status, and thus subject the plan to certain PPACA requirements from which grandfathered plans are exempt. In addition, this Alert describes employer/group health plan notification obligations which are effective prior to 2012.

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