Post on 08-Aug-2020
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Employer Responsibilities Under the Affordable Care Act:
Navigating the Complexities in 2014 and Beyond
* This outline is intended for general information
purposes and does not and is not intended to constitute legal advice. © 2014 Ice Miller LLP
Corn Belt Seed Conference
February 6, 2014
Indianapolis, Indiana
Sarah K. Funke
Ice Miller LLP
One American Square
Suite 2900
Indianapolis, IN 46282-0200
Phone: (317) 236-5883
Sarah.Funke@icemiller.com
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Individual Mandate
Health Care Exchanges
Expansion of Medicare/Medicaid
New Fees and Taxes
Pay or Play – Employer Shared Responsibility
New Reporting Requirements
Expansion of Employer Coverage – "Coverage Mandates"
What is Health Care Reform?
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Everyone – all individuals and all employees
Largest piece of employee benefit legislation ever – bigger than ERISA
Involves more federal agencies than any prior piece of benefits legislation:
DOL
IRS
Health & Human Services
Also involves States (State Departments of Insurance, Exchanges, etc.)
Who Does it Affect?
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General rule that individuals must either secure
"minimum essential coverage" or pay a tax
penalty. Must sign up by March 31, 2014.
Tax penalty
Taxpayer pays for him/herself and for tax
dependents.
No penalty if gap in coverage is less than 3 months.
Certain exemptions are available.
Individual Penalties - 2014
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Annual penalty is the greater of (1) a flat dollar
amount per individual (capped at 300% of the
flat dollar amount), or (2) a percentage of the
individual’s taxable income:
Individual Penalties – 2014 (cont'd)
5
Year Penalty for Lacking Coverage (Half for Child Under 18)
2014 $95 per adult or 1% of household income over the threshold
2015 $325 per adult or 2% of household income over the threshold
2016 $695 per adult or 2.5% of household income over the threshold
2017 Flat dollar amount (indexed for cost of living) or 2.5% of household income over the threshold
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PPACA Exchanges are "marketplaces" through which
individuals and small employers (up to 100
employees) can purchase coverage.
Beginning in 2017, States may allow businesses with
more than 100 employees to purchase health insurance
through the Exchange in that State.
Who Runs the Public Exchanges?
State
Federal Government
Both
Understanding Public Exchanges
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What Do the Public Exchanges Do?
Certify health plans as "qualified health plans"
Determine exemption from the individual coverage mandate
and whether "affordable" and "minimum value" coverage is
available to an individual
Make eligibility determinations for Medicaid, CHIP, etc.
Administer
Operate a toll-free information line
Maintain an Internet website that allows consumers
to compare available plans
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Understanding Public Exchanges (cont'd)
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One-Stop Shop
Exchange provides one-stop shopping with
"apples-to-apples" comparisons and a single
place to enroll employees and remit premiums.
Educate
Establish the Navigator program to award grants
for education and outreach regarding the
qualified health plans available through the
Exchange and facilitation of enrollment.
Understanding Public Exchanges (cont'd)
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PRIVATE EXCHANGES
Private exchanges existed pre-ACA.
Privately-run exchange contracts with participating
insurers.
Can be single-carrier (e.g., insurer operates and offers
only its own products) or multi-carrier (e.g., third party,
such as a broker, operates and offers products of
multiple insurers).
Serves as an online marketplace through which
employees can purchase health insurance and evaluate
differences among carriers and their plan designs.
Understanding Public Exchanges (cont'd)
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PRIVATE EXCHANGES
"Defined Contribution" approach: Employer gives each
eligible employee a fixed dollar amount for either
individual/family coverage, regardless of the plan the
employee chooses.
Unlike the public exchanges, no federal premium
subsidy is available to lower-income employees who
purchase insurance through a private exchange.
Public Exchange vs. Private Exchange: What's the
difference?
They differ in several important ways:
Understanding Public Exchanges (cont'd)
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PRIVATE EXCHANGES
Employer still needs to consider "group health plan" compliance issues.
Understanding Public Exchanges (cont'd)
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Premium assistance tax credit subsidies and cost
sharing assistance to individuals between 100% and
400% of federal poverty level (FPL)
Subsidies on a sliding scale based on income
Premium assistance tax credit - refundable and advanceable
Cost sharing assistance
Not available to individuals eligible for public plans (e.g.,
Medicaid) or who are eligible for affordable employer coverage
that has minimum value
Employees eligible for employer coverage generally are
not eligible for subsidies.
Public Exchange Subsidies
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However, an employee can qualify for a Federal tax subsidy if:
the employee purchases coverage on an Exchange; and
the employee's household income is between 100% - 400% of the federal poverty level; and
EITHER:
the employer does not offer minimum essential coverage; OR
the employer offers coverage that is not affordable for the employee or that does not provide minimum value.
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Public Exchange Subsidies (cont'd)
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The premium
assistance tax credit
is calculated based
on:
premium cost of the
second-lowest-cost
"Silver" plan offered
through a State
health benefit
exchange; and
income level of the
applicant
Public Exchange Subsidies (cont'd)
Income Level (% above
federal poverty level)
Maximum Premium as % of income that person has to
pay
Up to 133% 2.0%
133-150% 3-4%
150-200% 4-6.3%
200-250% 6.3-8.05%
250-300% 8.05-9.5%
300-400% 9.5%
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The 2013 Poverty Guidelines for the 48 Contiguous
States and the District of Columbia
Public Exchange Subsidies (cont'd)
Persons in family Poverty Guideline 133% 400%
1 $11,490.00 $15,281.70 $45,960.00
2 $15,510.00 $20,628.30 $62,040.00
3 $19,530.00 $25,974.90 $78,120.00
4 $23,550.00 $31,321.50 $94,200.00
5 $27,570.00 $36,668.10 $110,280.00
6 $31,590.00 $42,014.70 $126,360.00
7 $35,610.00 $47,361.30 $142,440.00
8 $39,630.00 $52,707.90 $158,520.00
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An employer is not required to provide coverage, but a Large Employer will face a tax penalty beginning January 1, 2015 (delayed from 2014), if the employer:
fails to provide minimum essential coverage to at least 95% of its full-time employees and their dependent children (up to age 26) [Penalty #1], OR
provides minimum essential coverage to at least 95% of its full-time employees and their dependent children (up to age 26) but such coverage is either not affordable or does not provide minimum value [Penalty #2].
Controlled group rules are not applicable for purposes of application of the employer penalties, but are applicable to determining Large Employer status.
Employer Shared Responsibility (Pay or Play):
What Is It?
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A "Large Employer" is an employer with 50 or more full-time employees (including full-time equivalents).
Large Employer status is determined based on average number of employees in previous calendar year.
For 2015, look to 2014 to determine status.
A month-to-month determination.
Special transition rule for 2013 allowing reference to a period of at least six consecutive calendar months in 2013. [We are not sure how this transition rule will be applied with the 2015 delay.]
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What is a "Large Employer"?
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Penalty #1 may apply if Large Employer does NOT
provide "minimum essential coverage" under an
employer sponsored health plan to at least 95% (or, if
greater, 5) ("substantially all") of its full-time employees
and their dependent children (to age 26). No penalty for failure to provide minimum essential coverage
to part-time employees.
Employer may provide group health plan coverage to part-time
employees, and such coverage would not be required to meet
minimum essential coverage, affordability, or minimum value
standards (but still has to meet coverage mandates under
PPACA and nondiscrimination rules).
Penalty #1: Employer Does Not Offer Coverage – 4980H(a)
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"Minimum essential coverage" (MEC) has the
same definition as applicable under individual
mandate, and is generally coverage under a group
health plan offered to an employee by an
employer, whether grandfathered or non-
grandfathered.
Penalty #1: Employer Does Not Offer Coverage – 4980H(a)(cont'd)
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Very general and vague definition – includes coverage
under: Medicare, Medicaid, CHIP, Tricare, veteran's plan, or Peace
Corps volunteer plan.
An employer sponsored plan (whether fully insured or self-
insured).
A health plan offered in the individual market within a State
(including fully-insured student health insurance).
A grandfathered health plan.
State health benefits risk pool, or other health benefits coverage
recognized by the Secretary of HHS for purposes of this
requirement (for 2014)
Self-insurance student health insurance (for 2014).
MEC is not required to cover essential health benefits.
Penalty #1: Employer Does Not Offer Coverage – 4980H(a)(cont'd)
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Minimum Essential Coverage does not include the following HIPAA-excepted benefits:
Limited scope dental and vision provided in a standalone plan
Most flexible spending account plans
Long-term, nursing home, home health, or community based care in a standalone plan
Accident only, disability, liability, workers compensation, automobile medical payment, credit-only insurance, on-site medical clinics
Coverage for a specified disease or illness, hospital indemnity or other fixed indemnity if under separate policy and no coordination with group health plan
Medicare supplemental health if separate policy
Employee assistance plans (EAPs) (and probably wellness programs)
Penalty #1: Employer Does Not Offer Coverage – 4980H(a)(cont'd)
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When minimum essential coverage is not offered to at
least 95% of full-time employees and their dependent
children (to age 26), a penalty is assessed if: One or more full-time employees purchase coverage from an
Exchange, AND
Any such employee qualifies for a Federal subsidy.
Penalty amount is $166.67 per month (or $2,000 per
year) for each full-time employee, regardless of how
many full-time employees purchase coverage from an
Exchange or qualify for a Federal subsidy. Penalty amount increased for inflation for years after 2015.
First 30 full-time employees exempted.
Penalty #1: Employer Does Not Offer Coverage – 4980H(a)(cont'd)
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Example: Employer A has 100 full-time employees and does not provide minimum essential coverage. Employee B purchases coverage through an Exchange and qualifies for a Federal subsidy.
Calculation of penalty:
Per Month = 70 employees (first 30 excluded) x $166.67 = $11,666.90
Per Year = 70 employees (first 30 excluded) x $2,000 = $140,000
Employer A is subject to a penalty of $11,666.90 per month or $140,000 per year.
Penalty #1: Employer Does Not Offer Coverage – 4980H(a) (cont'd)
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Penalty #2 may apply if Large Employer
provides minimum essential coverage to at
least 95% of its full-time employees and their
dependent children (up to age 26), but the
coverage:
does not provide "minimum value," or
is not "affordable" with respect to at least one full-
time employee.
Penalty #2: Employer Coverage Does Not Provide
Minimum Value or is Not Affordable – 4980H(b)
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Coverage provides "minimum value" if its actuarial
value is at least 60%, e.g., the plan would pay for at
least 60% of medical expenses on average for a
standard population and for allowable charges.
Coverage is not affordable with respect to an
employee if the employee's required contribution for
self-only coverage under the employer plan
exceeds 9.5% of household income. Look to lowest
cost coverage that employer sponsors that provides
minimum value.
Penalty #2: Employer Coverage Does Not Provide
Minimum Value or is Not Affordable – 4980H(b) (cont'd)
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When coverage offered is not affordable or does not
provide minimum value, a PENALTY is assessed if: One or more full-time employees opt-out of employer coverage and purchase coverage from an Exchange, AND
Any such employee qualifies for a Federal subsidy.
Penalty amount is $250 per month (or $3,000 per year)
for each full-time employee who opts out and qualifies for
a Federal subsidy. Penalty amount increased for inflation for years after 2015.
The penalty is capped at $2,000 per year times total
number of full-time employees, with first 30 full-time
employees exempted. [following Penalty #1] Penalty amount increased for inflation for years after 2015.
Penalty #2: Employer Coverage Does Not Provide
Minimum Value or is Not Affordable – 4980H(b) (cont'd)
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Affordability Example: Employer C has 100 full-time employees
and provides minimum essential coverage to all full-time employees
and their dependents.
Employee D's household income is $15,000, and he is charged $1,500 for
coverage under Employer C's plan, or 10% of his household income. Thus,
the coverage is not affordable with respect to Employee D.
Employee D opts out of Employer C's health plan, purchases coverage through
an Exchange, and qualifies for a Federal subsidy.
Employer C is subject to a penalty of $250 per month (or $3,000 per year) for
Employee D.
If any other employee of Employer C is similarly situated, Employer C will pay
the same penalty with respect to each such employee, capped at $140,000.
Calculation of maximum: 70 employees (first 30 excluded) x $2,000 = $140,000.
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Penalty #2: Employer Coverage Does Not Provide
Minimum Value or is Not Affordable – 4980H(b) (cont'd)
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To avoid penalties, an employer must offer coverage to:
All but 5% or (if greater) 5 of employer's full-time employees. Natural born, adopted, step, and foster children up to age 26.
An employer does not have to offer coverage to spouses to avoid penalties.
Spousal carve-outs still available.
Employees must have "effective opportunity" to elect coverage or to decline coverage that is not affordable or that does not provide minimum value, at least once a plan year.
Offering Coverage
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A full-time employee is a common law employee who is employed :
on average at least 30 hours of service per week; or
130 hours of service in a month.
Hours of service means:
each hour for which an employee is paid, or entitled to payment, for the performance of duties for the employer; and
each hour for which an employee is paid, or entitled to payment, for the period of time where no duties are performed due to vacation, holiday, illness, incapacity (including disability), layoff, jury duty, military duty, or leave of absence
What is a "Full-Time Employee"?
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All paid leaves must be included, and there is no
limitation on the amount of paid leave.
Hours do not include hours worked outside of the
U.S.
Employee may be classified as part-time, but
employee actually works an average of 30 or more
hours per week
What is a "Full-Time Employee"? (cont'd)
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Must count all common law employees (authority to
direct and control the manner in which services are
performed (actual control not required)).
Are these individuals common law employees?
Independent contractors
Staffing agency individuals
What is a "Full-Time Employee"? (cont'd)
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Employers may be tempted to substitute independent contractors to:
Avoid the cost of healthcare; or
Avoid the penalties that would apply for failing to offer coverage to full-time employees.
Under health care reform, an "employee" means a common-law employee. Employers who misclassify workers may be exposed to payment of past employment taxes, as well as health care reform penalties.
The IRS is increasing its focus on worker reclassification.
What is a "Full-Time Employee"? (cont'd)
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For hourly employees, count actual hours from
records of hours worked or for which payment is
made or due for vacation, holiday, illness, incapacity
(including disability), layoff, jury duty, military duty,
or leave of absence.
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What is a "Full-Time Employee"? (cont'd)
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For employees not paid on an hourly basis:
count actual hours same as for hourly employees;
or
use a days-worked equivalency of 8 hours of
service per day for each day employee would be
required to be credited with at least one hour of
service; or
use a weeks-worked equivalency of 40 hours of
service per week for each week employee would be
required to be credited with at least one hour of
service.
What is a "Full-Time Employee"? (cont'd)
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IRS recognizes that a determination of full-time employee status on a month-to-month basis causes practical difficulties for employers, employees, and Exchanges, particularly if workforce is such that employees have varying hours or employment schedules.
Accordingly, proposed IRS regulations provide for "safe harbor" methods that an employer may use to determine the full-time status of the following:
ongoing employees,
newly-hired "full-time" employees,
newly-hired variable hour employees, and
newly-hired seasonal employees.
What is a "Full-Time Employee"? (cont'd)
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What is a Full-Time Employee, and Counting
Hours (cont'd)
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So how are employers responding to these
rules in the Pay or Play Regulations?
There is talk of using many more part-time workers.
There is no penalty for not providing health coverage
to part-time employees.
Early statistics do not show a movement to part-time.
Why? Because a tradeoff between having a skilled
work force and reducing benefit costs.
Concern of the Complexity of Counting Employees and the Impact on Hiring
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Negatives of an increased part-time work force:
Competitive reasons
More administrative work and management
More supervisory time needed for training and
supervising
Supervisors will now need to manage hours more
closely – will have to educate numerous supervisors
on the very complex rules associated with counting
hours
More time spent hiring and on the hiring process
Concern of the Complexity of Counting Employees and the Impact on Hiring
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PPACA establishes a new "Patient-Centered Outcomes Research Institute" or "PCORI", a private non-profit whose mission is to research the outcomes and clinical effectiveness, risks, and benefits of medical treatments to help with informed health decisions.
PCORI is funded in part by a fee paid to Treasury by the:
Insurer for a fully-insured accident or health insurance policy
(including a policy under a group health plan) issued with
respect to individuals residing in the U.S.; and
Plan sponsor (generally, the employer) for any plan providing
accident or health coverage if any portion of the coverage is
self-insured and if the plan is established and maintained by
an employer for its employees.
NEW FEES AND TAXES
PCORI Fees
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When is the Fee Due?
Payable for the policy or plan years ending on or
after October 1, 2012, and before October 1, 2019
(for calendar year plans, 2012 through 2018).
Due by July 31 of the year following the last day of
the plan/policy year (by July 31, 2014 for 2013 for
calendar year plan) on IRS Form 720, Quarterly
Federal Excise Tax Return Form.
PCORI Fees (cont'd)
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What is the Fee Amount?
$2 times average number of lives (employee,
spouse, dependents) under policy/plan for the plan
year, for policy/plan years ending on or after October
1, 2013 (for calendar year plan, 2013).
Indexed for policy/plan years ending on or after
October 1, 2014.
Fee amount is that in effect on last day of applicable
policy/plan year.
Based on average number of lives for plan/policy
year – special rules for counting.
PCORI Fees (cont'd)
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PPACA establishes a transitional reinsurance
program to stabilize premiums for the individual
market during first three years of operation of
Exchanges.
Program funded by fees paid by: Health insurance issuers for fully-insured group health
plans that provide major medical coverage, and
Plan sponsors for self-insured group health plans that
provide major medical coverage.
Fee applies to "major medical coverage," whether
grandfathered or not.
Reinsurance Fees
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How Are Fees Assessed? Fees are assessed on a per-covered-life basis
(employee, spouse, dependent). Rules for
counting lives are not exactly the same as for
PCORI fees.
Fees must be paid for the calendar years 2014,
2015 and 2016.
Annual enrollment counts due to the Department of HHS
on November 15, 2014, 2015, and 2016.
HHS will notify of amount due within 15 days thereafter
or December 15 if later.
Reinsurance Fees (cont'd)
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Plan sponsors/issuers will be responsible for making payment within 30
days of notice of liability. Proposed to be paid in 2 installments.
Fee calculation is done on calendar year basis (unlike PCORI Fee,
which is based on Plan year).
Proposed regulations provide that the flat per capita per month amount for 2014 would be $5.25 per covered life per month, or $63 per covered life for the year.
Example: 5,000 covered lives x $63 = $315,000
Amount will go down for 2015 ($44) and then again for
2016.
Reinsurance Fee can be paid by TPA (unlike PCORI Fees) and deducted as a reasonable business expense
Reinsurance Fees (cont'd)
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Effective January 1, 2018, employer –sponsored health coverage that is "high cost" is subject to an excise tax.
Tax is equal to 40% of "excess benefit."
The "excess benefit" is the amount of annual coverage that costs more than $10,200 for single coverage and more than $27,500 for family coverage (limits may be adjusted before 2018).
Tax paid by insurer if fully-insured group health plan and by plan sponsor if self-insured group health plan.
Tax applies to group health coverage, including contributions made to health reimbursement accounts, salary-reduction contributions to a health FSA, and employer contributions made to an HSA.
Cadillac Tax
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Exchange Notice
Employers governed by FLSA are required to provide to each employee at the time of hire a written notice of the coverage options available through the Exchanges.
Notice must be provided to all employees (full-time or part-time and regardless of health plan eligibility):
For employees employed prior to October 1, 2013: By October 1, 2013
For new hires after October 1, 2013: Within 14 days after the employee's start date
DOL has provided model notices (one for employers that offer health coverage and one for employers that do not).
Notices explain:
Existence of Exchanges
Potential eligibility for a premium tax credit on the Exchange
Potential to lose employer contribution to employer health benefits and tax exclusion if employee purchases coverage on an Exchange
NEW EXCHANGE RELATED REPORTING
REQUIREMENTS
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New tax reporting requirements are foundation of
IRS enforcement of tax provisions of PPACA:
Individual mandate
Employer mandate
Premium tax credits
One year delay in reporting requirements.
Calendar year reporting regardless of plan year.
Important to have systems in place to track required
information by January 1, 2015.
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NEW EXCHANGE RELATED REPORTING
REQUIREMENTS (cont'd)
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Code Section 6055 Reporting: Insurer if a fully insured group health plan, or employer if a self-insured group health plan, must report coverage information to IRS in a new annual return to ensure that individuals are complying with the individual mandate and obtaining minimum essential coverage.
Voluntary for 2014; mandatory for 2015.
Report to employees by January 31, 2016 and to IRS by February 28, 2016 (March 31, 2016, if filed electronically).
NEW EXCHANGE RELATED REPORTING
REQUIREMENTS (cont'd)
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Code Section 6056 Reporting: Large Employers
(within the meaning of the employer shared
responsibility requirements) must report certain terms
and conditions of the health care coverage provided to
full-time employees for the year to IRS in a new annual
return for IRS to determine whether employer provides
adequate coverage to avoid employer shared
responsibility penalties.
Voluntary for 2014, mandatory for 2015.
Report to employees by January 31, 2016 and to IRS by
February 28, 2016 (March 31, 2016, if filed electronically).
NEW EXCHANGE RELATED REPORTING
REQUIREMENTS (cont'd)
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Summary of Benefits and Coverage (SBC)
W-2 reporting of cost of group health plan
coverage
Health FSA limit reduced to $2,500
Effective for plan years beginning on or after January 1,
2013.
Plans must be amended by December 31, 2014.
Initial coverage mandates
2013 Responsibilities (Ongoing)
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Initial Coverage Mandates
Initial Coverage Mandate
Applicable to
Grandfathered Plans?
No pre-existing conditions for < age 19 Yes
No lifetime or annual dollar limits (other than restricted annual limits) on EHBs
Yes
Adult child coverage (to age 26) Yes
No rescissions Yes
First dollar preventive health care coverage No
Internal and external appeals process No
Mandated patient protections No
Non-discrimination rules extended to insured plans (delayed enforcement)
No
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Second group of coverage mandates for group health plans effective for plan years beginning on or after January 1, 2014.
2014 Coverage Mandates
New Coverage Mandate Applicable to
Grandfathered Plans?
No pre-existing conditions for any enrollee Yes
No exclusion of adult children who have
coverage through employer Yes
No restricted annual limits Yes
No waiting period in excess of 90 days Yes
Limits on cost-sharing No
Mandated coverage of clinical trials No
No discrimination based on health status No
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PPACA increases the amount that an employer can reward employees for participation in a wellness program to up to 30% of the cost of health coverage, effective January 1, 2014.
Under final Federal regulations, the reward can be up to 50% of the cost of health coverage in connection with a program designed to prevent or reduce tobacco use.
Still have to comply with other laws, such as Americans with Disabilities Act, Genetic Information Nondiscrimination Act, ERISA, the Internal Revenue Code, etc.
Final regulations add much more complexity.
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Wellness Programs
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Employers subject to the Fair Labor Standards Act
must automatically enroll new full-time employees in
the employer’s health plan if:
employer has more than 200 full-time employees;
and
employer offers employees enrollment in one or
more health benefits plans.
Employers may still enforce waiting period if the
plan imposes one.
Automatic Enrollment
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The automatic enrollment program must include
adequate notice and the opportunity for an employee to
opt out of any coverage in which the individual was
enrolled.
Pre-empts state wage payment laws if they prevent
automatic enrollment.
Not yet clear into which of an employer’s plan options an
individual will be automatically enrolled.
Will be effective according to regulations to be issued by
Department of Labor (DOL), and DOL has said that it
does not expect to issue regulations before 2014.
Automatic Enrollment (cont'd)
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Nondiscrimination rules under Code Section 105(h)
already apply to self-insured group health plans.
Extension of similar rules relating to eligibility and
benefits to fully-insured non-grandfathered group
health plans.
Could impact fully-insured plans for executives as
well as fully-insured plans where employer pays
greater percentage of premiums for higher-paid
employees.
Nondiscrimination Rules for Insured Plans
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Could affect severance agreements.
Consider just grossing up severance payment equal to COBRA
premium.
Tax executive on the amount of the employer-provided
premium.
Not clear that these methods will work until guidance is
released.
Treasury expected to issue new regulations addressing
nondiscrimination under Code Section 105(h) for self-insured
plans, but Secretary of HHS is responsible for regulations for
fully-insured plans - expect new emphasis on compliance.
No enforcement until regulations issued.
Nondiscrimination Rules for Insured Plans
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Increase in part-time workers (?)
Less generous or no coverage for part-time workers.
More employers are looking to go self-insured due to expected increase in fully-insured rates.
Higher premium costs for most employees.
What is the Fall-Out of Health Care Reform?
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Unfortunately, the expansive nature and
complexities of health care reform require a
"village" of personnel to manage it.
More than ever before, in light of the numerous
pages of law and regulations to date, employers
need lots of help to ensure compliance.
It Takes a "Village"
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Players that are needed include:
Talented HR personnel.
A coordinated effort between HR, Finance, IT, and
Payroll like never before.
A deep compliance bench, typically provided by
outside ERISA legal counsel.
Engaged vendors, such as TPAs for self-insured
plans.
Knowledgeable brokers who are on the front line with
providers/vendors on product development.
It Takes a "Village"
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Engaged health care providers who will
actively participate in plan design
changes.
Good communication with employees to
assure them that you are all on the
same team trying to figure out what is
best for them and you.
It Takes a "Village"
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Department of Labor (DOL) website: http://www.dol.gov/ebsa/healthreform/
Health and Human Services (HHS) Health Reform website: http://cciio.cms.gov
Internal Revenue Service (IRS) website: http://www.irs.gov/uac/Affordable-Care-Act-Tax-Provisions
The preventive services list on the HealthCare.gov website: http://healthcare.gov/prevention/index.html
Resources
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