Human Resources

The Washington Report

February 27, 2019


Departments Request Information Regarding Grandfathered Group Health Plans and Grandfathered Group Health Insurance Coverage

On February 25, 2019, the Departments of Treasury, Labor, and Health and Human Services (the Departments) published a Request for Information (RFI) on grandfathered group health plans and group health insurance coverage. The Departments issued the RFI to gather input from the public in order to “better understand the challenges that group health plans and group health insurance issuers face in avoiding a loss of grandfathered status, and to determine whether there are opportunities for the Departments to assist such plans and issuers, consistent with the law, in preserving grandfathered status of group health plans and group health insurance coverage in ways that would benefit employers, employee organizations, plan participants and beneficiaries, and other stakeholders.” The RFI includes questions asking for feedback in various areas, such as actions the Departments can take to assist group health plan sponsors and group health issuers preserve the grandfathered status; challenges employers experience retaining such coverage; as well as the costs, benefits, and other factors involved when choosing to retain grandfathered status.

Comments on the RFI are due no later than March 27, 2019.

The RFI is available here.

If you elect to comment or engage with our content via third-party social media websites, you authorize Aon to have access to certain social media profile information. Please click here to learn more about information that may be collected when using these tools on

Find office locations