The Patient Protection and Affordable Care Act, enacted by President Obama on March 23, 2010, will change the way businesses provide and individuals purchase health insurance.

While most PPACA rules take effect in 2014, some health insurance reform changes go into effect before then. On June 28 the Departments of Labor, Treasury and Health & Human Services published temporary regulations and asked for comments on some of the changes that take effect Sept. 23, 2010.

The June 28 regulations outline new rules for group health plans on preexisting-condition exclusions for enrollees 19 years old or younger; annual and lifetime limits on coverage for “essential health benefits”; rescinding coverage; and new patient protections. 

Of particular interest to restaurateurs, the rule allows employers to seek waivers from the law’s annual-limit restrictions. This will affect an employer’s ability to offer limited benefit or “mini-med plans” to their employees.

The National Restaurant Association submitted comments to all three departments last week regarding the regulations. Among the requests the NRA made:

* Until PPACA guidelines and standards are clear, agencies should not retroactively penalize employers who try in good faith to comply with the law when guidance has not yet been issued -- especially on what constitutes “essential health benefits.”

* Agencies should make sure that limited-benefit or “mini-med” plans remain an option for employers until alternatives are available in 2014. The NRA noted this could be achieved either by allowing a blanket waiver for limited-benefit programs with annual coverage limits; or by creating a case-by-case waiver program that would be quick and easy for employers to use. Many employers offer limited-benefit plans to part-time, seasonal and temporary employees, and employees who are waiting to become eligible for regular health plans.

Read the NRA's comments here, and read about our comments on previous regulations.