"Not Your Grandfather’s Grandfather: Interim Grandfather Rules Released Under Health Care Legislation"

Last week, the Federal agencies charged with implementing the Patient Protection and Affordable Care Act (the "Act") issued interim guidance on the Act's grandfather provisions.  Although the impact of this guidance on plans, plan sponsors, plan administrators and insurance companies could vary depending on individual circumstances, the attached chart is intended to give a general overview of selected considerations addressed by the interim guidance.  Given the scale, scope and details involved in the grandfather provisions, the interim rules may not be as illuminating as many would have hoped for.