Originally Published to Humana’s May 2015 Newsletter | May 7, 2015
Humana has made a decision about the dependent age limit as it applies to compliance with the Affordable Care Act (ACA) Employer Shared Responsibility mandate, which was effective 1/1/2015. This mandate defines a child as a dependent for the entire calendar month during which he or she attains age 26. In comparison, the ACA mandate for covering adult children, which went into effect for plans issued on or after 9/23/2010, allowed termination of dependent coverage on the dependent’s 26th birth date. After 2015, employers could be subject to penalties if they don’t cover dependents for the entire calendar month during which they attain age 26.
Humana found that many of their Small Business customers already have the end-of-the-month term provision in place. Humana is working with IT to systematically update all Commercial Group FI business, both Large Group and Small Business, to change the dependent termination rule to the end of the month in which the dependent attains age 26. The mandate applies to Medical business only. However, if there are ancillary products in the same division as the Medical benefit, then Humana will apply the term provision to all products in that division. Note: Humana is including all Small Business groups, including ancillary only groups, in the update to ensure consistency.
Humana is not including ASO group plans in this proactive update. Our ASO groups will need to determine when their plan must comply with the Employer Shared Responsibility mandate and request an update to their termination provision if desired. Any changes to the termination provision will follow normal process and will require a change notice.
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