Health Care Reform Alerts!
Still not sure if your company is required by ACA to make health coverage available to employees?
You are not alone. Many business owners with approximately 50 employees are unsure as to how to make this determination. We can help with that. Also, the IRS has created a webage on irs.gov that provides a lot of resources to help you determine your obligations under the law. Click this link to go to the IRS ACA Information Center for Applicable Large Employers (ALEs)
How will I know if one of my employees gets a subsidy from the goverment to purchase individual health insurance on the marketplace? CMS - Employer Notification Program - Spring 2016
Center for Medicare & Medicaid Services (CMS) has announced that beginning Spring 2016 CMS will notify Applicable Large Employers (ALEs) when an employee receives a "subsidy" to purchase individual health insurance on the Marketplace. Click this link to see a CMS FAQ with details on the Employer Notification Program. CMS FAQ - 2016 Employer Notice Program
Section 6056 ACA Employer Reporting Requirements - FILING DEADLINE MARCH 31, 2016
If you have 50 or more full-time employees (including full-time equivalent employees) ACA requires you to file a return that reports summary information for your company (Form 1094-C "Transmittal Form" ) as well as a return that reports information for each respective employee ( Form 1095-C "Employee Statement" ).
Click this link to see a FAQ developed by the IRS for 6056 Employer Reporting: IRS Q&As 6056 Reporting
It is this reporting that the IRS will use to enforce both the employer mandate and the individual mandate and also for determining premium subsidy eligibility for individuals who attempt to obtain subsidized coverage through either the Federally Facilitated Marketplace (www.healthcare.gov) or applicable State Marketplace.
Although the electronic filing deadline is not until March 31, 2016 (paper filing deadline is February 28, 2016), employers need to be tracking each employee month by month during 2015 in order to accurately prepare and submit the Form 1095-C "Employee Statement".
Health Care Reform - Great Info Resources
For Employers with fewer than 50 Employees
Although the ACA does not require Employers with fewer than 50 employees to provide coverage, Group Health Insurance for these groups is impacted. Examples include:
- Premium Rates can no longer be based upon health history or claims history
- Pre-Existing Condition Exclusions Prohibited
- No Lifetime Limits
- Plans must cover specified Preventative Health Services at 100%
- Dependent Child Coverage extended to 26th birthday
- Maximum Out of Pocket cannot exceed $6,600 per year Single / $13,200 Family
- Must include ACA specified “Essential Health Benefits”
- Provide Pediatric Dental and Vision coverage for Dependent Children under age 18
- Premium rates calculated on Modified Community Rating Basis
- Several ACA fees included in premiums and paid to the government by insurers
- Eligibility Waiting Period cannot exceed 90 days
- Plans must be labeled according to their relative Actuarial Value by “Metallic Level”
A few key discussion points:
- Some insurers will still allow employers to retain limited eligibility (ex: Salaried Only, etc)
- Some employers may actually be doing employees a disservice by providing Group Health Insurance coverage as it may disqualify them from ACA Premium Subsidies
- Some groups may be best served by considering alternatively funded Health Plans
- If you currently have a Group Health Insurance plan, your insurer has most likely automatically made changes to your plan to reflect these requirements unless you have chosen to retain a “Grandfathered”. In some cases, insurers have allowed “Grandmothered” plans which may be more costly than an ACA compliant plan
- Defined Contribution strategies allow Employers to establish a fixed budget amount and provide employees with flexible, fully customizable mix of benefits to fit their specific situation
We can help you navigate these changes and develop a custom solution – good options are still out there!