Publications

The Massachusetts Health Care Reform Act Revisited: Proposed Regulations Help Fill in the Gaps
07/27/2006

At the end of June, the Massachusetts Division of Health Care Finance and Policy released three proposed regulations clarifying certain obligations that the new Massachusetts health care reform act (the Act) imposes on employers doing business in Massachusetts, as reported in the Seyfarth Shaw May 2006 Management Alert. In that Alert, we discussed four key employer mandates set forth in the Act. The proposed regulations provide guidance on the health information disclosure form, the free rider surcharge and the fair share contribution, but offer no guidance on the content or form of the cafeteria plan contemplated by the Act. Moreover, they remain “works in progress”: hearings on the proposed regulations will occur this year on August 8 (fair share contribution (morning) and free rider surcharge (afternoon)) and August 15 (disclosure requirement), after which the Massachusetts Legislature will review, and perhaps revise, the regulations. The legistlature may factor into the balance the recent court decision concerning Maryland’s “fair share” statute, as discussed in this Alert.


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