Key takeaways 

• Many employers are in the process of ensuring that their medical plans comply or will be ready to comply with the various provisions of the Patient Protection and Affordable Care Act of 2010 (the “ACA”) as they become effective.
• Several of those provisions, such as rules prohibiting insured plans from discriminating in favor of highly compensated employees, rules limiting cost sharing with employees, and rules requiring external appeals review, do not apply to so-called “grandfathered” plans.
• As employers prepare for this upcoming healthcare plan enrollment period, this Client Update serves as a refresher course to help them determine whether their health care plans are “grandfathered” and understand which provisions of the ACA do and do not apply to their grandfathered plans.