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April 16, 2014

Proposed Regulations Addressing Multi-State Plans

As part of the regulations under the Patient Protection and Affordable Act (PPACA), the U.S. Office of Personnel Management (OPM) proposed a requirement that OPM contract with private health insurance companies to ensure that at least two multi-state plans are offered in each state’s Affordable Insurance Exchange.   Under the law, a multi-state plan issuer may phase in the states in which it offers coverage over four years, but must offer a multi-state plan in exchanges in all States and the District of Columbia by the fourth year.  The proposed regulations generally address OPM’s approach to the offering of multi-state plans and the attributes of the multi-state plans to be offered.  Comments are being solicited, and are due within 30 days after the rules are published in the Federal Register, which is expected to take place this week. 

© 2014 McDermott Will & Emery

About the Author

Partner

Amy Gordon is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Chicago office.  She focuses her practice on the areas of welfare benefits, including self-funded and insured health plans. She assists clients in designing and maintaining compliant flexible benefit, life, medical, dental, pharmacy, EAP, educational assistance, disability, supplemental health, severance, Health Savings Accounts, Health Reimbursement Accounts, and other types of welfare plans.  She counsels clients with respect to HIPAA, ERISA and the Internal Revenue Code...

312-984-6931

About the Author

Partner

Susan M. Nash is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Chicago office.  Susan focuses her practice primarily in the area of health and welfare benefit plans, including compliance with COBRA, HIPAA, ERISA, the Affordable Care Act, the Internal Revenue Code, and other federal laws affecting group health plans.

312-984-7660
Associate

Jacob Mattinson is an associate in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Chicago office.  He focuses his practice on matters related to employee benefits and executive compensation.

312-984-3263

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