This week the nation is expected to hear the U.S. SupremeCourt's decision regarding the Patient Protection and AffordableCare Act, but that doesn't mean credit unions can afford to simplywait and see.

According to Brad Pricer, human resources process leader at CUNAMutual Group who has been helping credit unions and leaguesnavigate healthcare reform, credit unions have plenty of complianceconcerns to address.

Pricer has said he doesn't expect the entire act to be thrownout and that credit unions need to be prepared.

Here's a quick, seven-part 2012 healthcare reform compliancechecklist courtesy of CUNA Mutual Group.

W-2 REPORTING

Beginning with the 2012 tax year,employers that are required to issue 250 or more W-2 Forms mustreport the aggregate cost of employer-sponsored group healthcoverage on employees' W-2 Forms.

The cost must be reported beginning with the 2012 W-2 Forms,which are issued in January 2013.

This requirement is optional for smaller employers for the 2012tax year – and until further guidance is issued.

Reporting is for informational purposes only – it does notaffect the taxability of benefits.

GRANDFATHERED PLAN STATUS

A grandfathered health plan is one that was in existence whenhealth care reform was enacted on March 23, 2010. Grandfatheredplans are exempt from some of the health care reform requirements.A plan's grandfathered status will continue to affect itscompliance obligations from year to year.

Determine if you have agrandfathered plan.

Determine whether your plan will maintain its grandfatheredstatus. If you make certain changes to your plan that go beyondpermitted guidelines, your plan is no longer grandfathered.

If you move to a non-grandfathered plan, make sure the planincludes all the additional participant rights and benefitsrequired by health care reform. These rules include first-dollarcoverage of preventive care services, an enhanced claim and appealprocess, and non-discrimination requirements for insured plans.

ANNUAL LIMITS

Beginning Jan. 1, 2014, group health plans will no longer beable to impose annual limits on the value of essential healthbenefits. However, until then, certain minimum annual limits arepermitted. Unless your plan received a waiver of the annual limitrequirements, you should confirm that any annual limit included inyour plan is set at least as high as the following amounts for eachapplicable plan year:

• $750,000 for plan years beginning on or after Sept. 23, 2010,but before Sept. 23, 2011;
• $1.25 million for plan years beginning on or after Sept. 23,2011, but before Sept. 23, 2012; and
• $2 million for plan years beginning on or after Sept. 23, 2012,but before Jan. 1, 2014.

SUMMARY OF BENEFITS AND COVERAGE

Plans and insurance issuers must provide a Summary of Benefitsand Coverage to participants and beneficiaries.

The SBC is a concise document – no more than four double-sidedpages – providing simple and consistent information about healthplan benefits and coverage in plain language.

A template for the SBC isavailable, along with instructions and examples for completing thetemplate and a uniform glossary of terms.

The final SBC regulations provide that plans and issuers muststart providing the SBC as follows:

Issuers must provide the SBC to health plans effective Sept. 23,2012.

Plans and issuers must provide the SBC to participants andbeneficiaries who enroll or re-enroll during an open enrollmentperiod beginning with the first day of the first open enrollmentperiod that begins on or after Sept. 23, 2012.

For participants who enroll in coverage other than through anopen enrollment period (for example, newly eligible individuals andspecial enrollees), plans and issuers must provide the SBCbeginning on the first day of the first plan year that begins on orafter Sept. 23, 2012.

60-DAY NOTICE OF PLAN CHANGES

Plans and issuers must provide 60 days' notice of any materialmodifications to the plan that are not related to renewals ofcoverage. Notice can be provided in an updated SBC or a separatesummary of material modifications.

WOMEN'S PREVENTIVE CARE GUIDELINES

Effective for plan years starting on or after Aug. 1, 2012,non-grandfathered plans must cover specific preventivehealth services for women with no costsharing. These services include well-woman visits, STD screeningand contraceptives. Exceptions to contraceptive requirements applyto religious employers.

MEDICAL LOSS RATIO REBATES

Fully insured plans may receive rebates in August 2012 if theyqualify for a rebate from their issuers due to the medical lossratio rules requiring insurance companies to spend a certainpercentage of premium dollars on health care. The rebates must beused for the benefit of the plan's enrollees, which may includereducing enrollees' premium payments.