August 05, 2014

logoThis Ask the Expert response was provided by

William J. Thompson, FSA, MAAA   |   Principal & Consulting Actuary   |
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Milliman   |   80 Lamberton Road   |   Windsor, CT 06095   |   USA
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From my perspective, I believe the driver is each employer having its own self-insured health plan.   The plan sponsor is responsible for complying with the requirements of PPACA; the fact that they are insuring a portion of their risk with an RRG doesn't affect that.

The only thing that may have an implication here is when an employer with a fully insured program becomes self-insured.   There are different (somewhat less stringent) requirements for self-insured groups than for insured groups.