Initially, the IRS outlined rules for the tax credit in Notice 2010-44. A follow-up document, Notice 2010-82, explained transition relief related to the rules for a qualifying arrangement and provided more details about the requirements. For example, Notice 2010-82 clarifies how an employer that offers more than one plan determines whether its contribution amount meets the threshold for a qualifying arrangement. The IRS has released several additional items related to the tax credit, including:
Determine how to implement the required 30-day enrollment period applicable to adult children up to the age of 26. Be sure notice of such enrollment right is provided in the appropriate manner to plan participants Model Notice
If coverage of any participant was previously terminated due to imposition of a lifetime maximum, determine how to implement the required 30-day re-enrollment period and provide the required notice of such re-enrollment right. Model Notice
If any of the health benefit plan options offered will be grandfathered, be sure that all open enrollment communications and other materials describing benefits offered under these grandfathered options contain the required disclosure regarding grandfathered status. Model Disclosure
For self-insured plans, carefully review and analyze current claims and appeals procedures and determine whether changes are necessary or desirable to the procedures and/or to administrative services agreements in light of the new claims, appeals and external review requirements.
Model notices designed to comply with these new rules can be found at
Determine whether disclosures regarding new Patient Protections are required. Disclosures