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Collectively Bargained Plans

Provisions effective 2010

Summary

For health insurance coverage maintained pursuant to one or more collective bargaining agreements (CBAs) ratified before March 23, 2010, many key provisions of the health reform law do not apply until the date on which the last of the collective bargaining agreements relating to the coverage terminates.

There are special rules for health insurance coverage maintained pursuant to one or more collective bargaining agreements ratified before March 23, 2010. Coverage will remain grandfathered at least until the date on which the last agreement relating to the coverage that was in effect on March 23, 2010 terminates. The Interim Final Rule (IFR) clarifies that the collectively bargained exception to grandfather status applies only to insured collectively bargained plans – not self-funded collectively bargained plans.

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