On May 24, 2016, the Virginia Bureau of Insurance published Administrative Letter 2016-04. The new letter is a summary of insurance-related legislation enacted by the 2016 Virginia General Assembly. The letter summarizes a few health insurance items, including Chapters 1 and 271.
Chapter 1 (covered in the March 22, 2016, edition of Compliance Corner, as “H 58”) states that the definition of “small employer” for group health insurance purposes will remain as an employer with an average of 50 or fewer employees. As a quick reminder, the federal PACE Act repealed a PPACA requirement that mandated states to define “small employer” as one with between one and 100 employees—and certain PPACA insurance mandates apply only to small employers. Chapter 1 confirms that Virginia will retain the lower threshold for small groups.
Chapter 271, enacted on March 7, 2016, authorizes carriers to sell, issue, offer or renew any non-PPACA-compliant health benefit plan to the extent the appropriate federal authority has suspended enforcement of the PPACA (or the requirements of PPACA are amended by any federal law).
The letter and new laws do not create any new compliance obligations for employers. Virginia employers that sponsor fully insured plans should be aware of the new laws, as they may impact the coverage their plans provide to covered employees and dependents.
Administrative Letter 2016-04 » Chapter 1 »Chapter 271 »
Chapter 1 »
Chapter 271 »