The look back measurement period applies to all employees within the same class (e.g. salaried or hourly) of applicable large employers (not just variable employees, for example).

An applicable large group employer member is not considered to have made an offer of coverage to a full-time employee unless the employee had the opportunity to elect coverage for his/her dependent children, if any. That coverage, if elected, would extend through the end of the month in which the child turns 26 (or if earlier, the date the coverage ended for the employee).

Section 6056 Reporting

This requires applicable large employer members to file an IRS form (similar to and in addition to a W-3) which identifies each of the employees who were full time at least one month of the calendar year and what, if any, coverage was offered. A form is also to be furnished to those full-time employees (similar to and in addition to a W-2)  – Forms (1094 and 1095-C).

Section 6055 Reporting

This requires minimum essential coverage providers to file an IRS form identifying each individual enrolled at least one day during that year. This applies to any employer who offers a self-insured plan and to individuals covered under the plan. The form also must be provided to covered individuals. Fully insured carriers will satisfy this obligation with respect to individuals covered under the policy. Employers sponsoring a self-insured plan are obligated to satisfy the requirement with respect to all individuals enrolled – Forms (1094 and 1095-B).

2014 Health Insurance Reforms: Waiting Period Limitation and Out of Pocket Maximum Requirements

PHSA Section 2708 generally limits waiting periods for otherwise eligible individuals to 90 calendar days. Regulations clarify that terms of eligibility generally cannot be based solely on the passage of time. Eligibility based on accumulated hours, not to exceed 1200, or a "measurement period" is permissible. Employers may implement a 30-day orientation period for employees who otherwise satisfy the eligibility requirement, after which the waiting period can begin.

In referencing FAQs provided by the agencies, there was no mention of the dollar amount associated with out-of-pocket requirements for "reference-based pricing arrangement." According to the FAQs, plans my treat providers who accept the plans "reference base pricing" as the only in-network providers, if certain conditions are satisfied. If those conditions are satisfied, then all services or treatment given by providers who did not accept the plans reference base pricing, including network providers, can be treated as out-of-network in the cost sharing for such services and fall outside the out-of-pocket maximum limitation. This is an important distinction because typically the out-of-pocket maximum imposed by health care reform applies to all cost sharing with respect to services or treatments provided by in-network providers, Cost sharing for out-of-network providers does not have to be applied to the out-of-pocket maximum.