IRS Requests Extension of Revised Information Collection on Grandfathered Health Plans; Comments Due December 11

Published October 09, 2023

The Internal Revenue Service (IRS) issued a notice soliciting comments concerning the burden associated with the rules for group health plans and health insurance coverage relating to status as a grandfathered health plan under the Patient Protection and Affordable Care Act (ACA). 

The notice:
  • Contains final regulations regarding grandfathered health plans, preexisting condition exclusions, lifetime and annual dollar limits on benefits, rescissions, coverage of dependent children to age 26, internal claims and appeal and external review processes, and patient protections under ACA; and 
  • Finalizes changes to the proposed and interim final rules based on comments and incorporates sub regulatory guidance issued since publication of the proposed and interim final rules. 

Adjustments to the burden estimates result from updated estimates on the number of grandfathered group health plans and increases in wage and postage rates. The updated data inputs reduce the hour burden by 1,550 hours compared with the prior submission and reduce the cost burden by $241,267 compared with the prior submission.