Under the Patient Protection and Affordable Care Act, not all rules are equal. Some requirements apply to all plans, but others don't apply to a particular plan if that plan qualifies for - and then maintains - "grandfather" status. The PPACA statute itself provides few specifics on how this is supposed to work, leaving it up to regulators at the Departments of Treasury and Health and Human Services to spell out the details. In response, regulators have issued two sets of guidance.

The first, and most substantive, came in June, in the form of interim final regulations. While these regulations provided much-needed specifics about what grandfathering under PPACA means to plan sponsors, the standards they set were higher than many had expected.

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