Grandfathering Documentation Requirements

A grandfathered plan must maintain records documenting the terms of health coverage in effect on March 23, 2010, and any necessary substantiating documentation. These records and documentation must be available to the agencies, participants or beneficiaries upon request, and must be sent to any new insurance carrier.  Federal guidance suggests that such documentation could include the following:

  • Plan documents, including amendments Health insurance policies
  • Certificates or contracts of insurance Summary plan descriptions
  • Documentation of plan design (including benefits, cost­-sharing and annual limits)
  • Documentation of premium rates and contributions (including total premiums, employer and employee contributions and, for self-funded plans, the total value of coverage)

Neither American Fidelity Assurance Company nor American Fidelity Administrative Services provides tax or legal advice and, given the complexity of these laws, we always recommend working with your legal counsel on how the laws impact your specific situation.