Insight to Action

Benefits & Healthcare Update: Agencies Finalize ACA Market Reform Rules, Make No Substantial Changes

4 December 2015

On November 18, 2015, the DOL, HHS, and IRS jointly published final rules on grandfathered plan status, pre-existing condition exclusions, lifetime and annual limits, rescissions, dependent coverage, appeals, and patient protections. The final rules formalize and merge the previously issued interim rules and sub-regulatory guidance. There are no substantial changes from the former interim rules and regulatory guidance issued by these agencies. The final rules become effective for plan years starting on or after January 1, 2017.

The final rules can be found here:

If you have any questions about the ACA market reforms, please contact Ed Doherty at 646-839-8251 or via
email at