Certain plan design changes must be made for the upcoming plan year, even if the plan is grandfathered. Other provisions of the Act may impact design and administration so sponsors will want to consider them now.
The first chart below applies to grandfathered and non-grandfathered plans.
The second chart lists those issues that only will apply to non-grandfathered plans. To the extent any of these items results in plan changes, employees will need to be notified, plan documents and open enrollment materials will need to be updated and administration will need to be changed accordingly.