are considering the impact of the upcoming change in the definition of
small employer to include 51-100 employees and are considering actions
to either move forward with the change or delay the expansion further.
More recently, the Nebraska Department of Insurance (DOI) stated in a notice
“the Obama Administration has indicated that those fully insured groups
that have 51-100 insureds may be allowed to keep their policies and
remain in the large group market via a transitional policy akin to the
transitional policies that were allowed in the small group market.” With
that in mind, the DOI will allow policies for groups sized 51-100 to
remain in place as transitional policies for as long as allowed by the
federal government’s current transitional policy guidance (October 1,
Rhode Island has also indicated a delay and would preserve the small group definition for 2016 in its entirety. And, in a Director’s Order, the Michigan Department
of Insurance and Financial Services (DIFS) has clarified that employer
groups with between 51 and 100 employees are permitted to purchase new
large group coverage until 12/31/15 and renew such coverage between
1/1/16 and 10/1/16.
New York and California have indicated their interest in moving forward with the expansion. We will continue to post updates on this issue within the Health Care Reform Open Forum in Dental Interact (DI).