Archives on July, 2015

Key Benefit Provisions that DO and DO NOT Apply to Grandfathered Plans

Posted by mnjinsurance on July 31, 2015

Group health plans in existence on or before March 23, 2010, when the Affordable Care Act was signed into law may be considered “Grandfathered.”  Grandfathered plans are exempt from certain health care provisions, whereas non-grandfathered plans must comply with health care reform mandates.  Listed below are a summary of key benefit provisions that apply to Grandfathered Plans, and a list of key benefit provisions that DO NOT apply to Grandfathered plans.

 

It is important to note, that NOT all health insurance carriers are allowing a “Grandfathered” plan option.  In mid 2014, the carriers in California that were allowing Grandfathered group plan options were Kaiser Permanente and Health Net.  The other group carriers in California discontinued the “Grandfathered plan options.”

 

Key Benefit Provisions That DO Apply to Grandfathered Plans

 

Many of the changes under Health Care Reform apply to all plans, regardless of grandfathered status. Key requirements that grandfathered group health plans must comply with include:

 

  • 90-Day Limit on Waiting Periods. In plan years beginning on or after January 1, 2014, group health plans may not apply any waiting period that exceeds 90 days.  A waiting period is the period  of time that must pass before coverage for an employee or dependent who is otherwise eligible to enroll under the terms of the plan can become effective.
  • Dependent Coverage to Age 26. Grandfathered group health plans that offer dependent coverage must continue to make the coverage available until a child reaches the age of 26, unless the adult child has another offer of employer-based coverage (such as through his/her job). Beginning in 2014, a child up to age 26 can stay on the parent’s plan, even if the adult child is eligible to enroll in another employer-sponsored health plan.  Eligible dependents can also remain on their parents’ health insurance plan if they are married, up to age 26.
  • Elimination of Preexisting Condition Exclusions. Group health plans cannot limit or deny benefits or coverage for a child younger than age 19 on the basis of a preexisting condition (a health problem that developed before the child applied to join the plan). Effective for plan years beginning on or after January 1, 2014, this rule applies to both children and adults.
  • Medical Loss Ratio (MLR) Rebates. Employers who sponsor group health plans and receive rebates, as a result of insurance companies not meeting specific standards related to how premium dollars are spent, may be responsible for distributing the rebates to eligible plan enrollees annually.
  • No Lifetime or Annual Limits. Group health plans may not impose lifetime limits on coverage of “essential health benefits.” Annual limits on essential health benefits are prohibited for plans issued or renewed beginning January 1, 2014. Until then, annual limits are being phased out according to the limits set by law.
  • Prohibition on Rescission of Coverage. Group health plans are not permitted to rescind health coverage (meaning declare the coverage invalid from the time of enrollment), except in the case of fraud or intentional misrepresentation by a person covered under the plan.
  • Summary of Benefits and Coverage (SBC). Effective for plan years and open enrollment periods beginning on or after September 23, 2012, group health plans and health insurance issuers offering group coverage are required to provide participants and beneficiaries with a summary of benefits and coverage at several points during the enrollment process and upon request.

 

Key Benefit Provisions That DO NOT Apply to Grandfathered Plans

 

Grandfathered group health plans are not required to comply with certain changes under Health Care Reform, including requirements relating to:

 

 

As always, if you would like to evaluate which option is best for your company, MNJ Insurance Solutions is available to assist you and review the pros and cons of each scenario.  For more information, please contact us at (714) 716-4303.

 

 

This content is provided for informational purposes only.  While we have attempted to provide current, accurate and clearly expressed information, this information is provided “as is” and MNJ Insurance Solutions makes no representations or warranties regarding its accuracy  and completeness.  The information provided should not be construed as legal or tax advice or as a recommendation of any kind.  External users should seek professional advice form their own attorneys and tax and benefit plan advisers with respect to their individual circumstances and needs.

 

 

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Grandfathered Plans

Posted by mnjinsurance on July 31, 2015

Group health plans in existence as of March 23, 2010, when the Affordable Care Act was signed into law may be considered “Grandfathered.” Grandfathered plans are exempt from certain health care reform provisions, whereas non-grandfathered plans must comply with the healthcare reform mandates. Group health plans with “grandfathered” status may have significant consequences if they change to non-grandfathered/ACA compliant plans, including an increase in the cost of benefits and change of benefits.

 

What changes trigger loss of “grandfathered” status?

 

Any one of the following plan changes will cause a grandfather group health plan to lose its “grandfathered” status:

 

  • An increase in percentage of cost-sharing requirement, such as coinsurance, regardless of the amount;
  • An increase in the deductible or out-of-pocket maximum by an amount that exceeds medical inflation, plus 15% points;
  • An increase in copayments (if the increase exceeds the greater of five dollars, adjusted for medical inflation or medical inflation +15% points);
  • A decrease in the employer’s contribution rate by more than 5% (measured for each tier of coverage);
  • Elimination of all or substantially all benefits to treat a particular condition;
  • Adding or decreasing a new overall dollar limit to the plan that was in a fact as of March 23, 2010; or
  • The carrier no longer offers “grandfathered” plans.

 

Any of the following changes in the plan may also trigger the loss of grandfathered status of the plan, depending on the level of change:

 

  • The addition of a new prescription drug tier with new cost-sharing;
  • An increase in cost sharing related to wellness incentives or penalties;
  • An increase in retiree self-pay rates;
  • Transfer of employees into a less generous plan or plan option where the transfer is not due to a bona fide employment-based reason; and
  • Certain changes made in response to the Mental Health Parity and addiction equity at, such as increasing cost sharing for medical/surgical benefits, instead of lowering cost sharing for mental health and/or substance abuse disorder benefits.

 

NOTE: The employer must include a notice about the plans grandfather status insignificant participant communications, such as enrollment materials and summary plan descriptions. The notice does not need to be included with the SBC or EOBs). A model notice is available at: DOL Grandathered Model Notice

 

 What changes do not trigger loss of “Grandfathered” status?

 

The U.S. Departments of Health and Human Services (HHS), Department of Labor  (DOL), and Department of Treasury recently amended the requirements for maintaining grandfathered status under health care reform. Effective November 15, 2010 you can retain your plans grandfathered status after changing carriers or moving from a self-insured to a fully insured plan, as long as you have not made other changes that would cause the plan to lose grandfathered status. In addition, changing third-party administrators, pharmacy benefit managers, or changing the plans networks will not cause a plan to lose its grandfathered status.

 

According to HHS, they estimate the following:

 

  • 40% to 67% of individual policies will lose grandfathered status by 2011;
  • 34% to 64% of large employer group plans (100 or more employees) will lose their grandfather status by 2013; and
  • 49% to 80% of small employer group plans (3 to 99 employees) Will lose their grandfather status by 2013.

 

Loss of grandfathered status coincides with the effective date of the design changes. Also, once an employer loses its grandfathered status, they cannot return to set status at a later date. With all of the changes with the affordable care act, the decisions of whether or not to remain grandfathered must be carefully considered, as it has broad implications for the health plan and it’s participants.

 

When is the last time you had an evaluation of your current benefits? Call MNJ insurance solutions for a consultation at (714) 716-4303.

 

Resources for Grandfathered Health Plans:

 

This content is provided for informational purposes only.  While we have attempted to provide current, accurate and clearly expressed information, this information is provided “as is” and MNJ Insurance Solutions makes no representations or warranties regarding its accuracy  and completeness.  The information provided should not be construed as legal or tax advice or as a recommendation of any kind.  External users should seek professional advice form their own attorneys and tax and benefit plan advisers with respect to their individual circumstances and needs.

Understanding the Metal Levels in ACA

Posted by mnjinsurance on July 30, 2015

With so many options to consider in small group employer plans, deciding on the best health care plan can be confusing. The affordable care act has made many changes to how the carriers create their plan designs. The insurance plans now use the following category levels: bronze, silver, gold, or platinum, based on how they cover the cost of care.

 

What do the metal levels mean?

 

The ACA plans must include a core set of benefits, called essential health benefits (“EHB”), including but not limited to the following: coverage for emergency room care, hospital stays, maternity and newborn care, prescription drugs, and preventive care. Plans and each tear pay different amounts of the total cost of an insured’s care.  For example, bronze plans have the lowest monthly premiums, but the insured pays more when they utilize health care services.  Platinum plans have the highest monthly premiums, but members pay the lowest cost share amounts when they utilize health care services.

 

The Four Metal Levels:

metal tiers

Bronze: health care plan pays 60%, member pays 40%.

Silver: health care plan pay 70%, member pays 30%.

Gold: health care plan pays 80%, member pays 20%.

Platinum: health care plan pays 90%, member pays 10%.

 

 

The metal level impacts not only the premiums, but also how much the member pays for services rendered, such as hospital visits or prescription drugs. Beyond the required essential health benefits, different plans may offer coverage for other services as well. It is important to note, not all metal plans are the same.

 

Important things to consider when selecting a health insurance plan:

 

  • It is important to look at the health insurance carrier’s network and see if your doctor is a participating provider. Most carriers offer a full network, reduce network, and or a reduced reduce network plan option.
  • It is important to research your prescriptions with the carrier and network you are considering, as the carriers include different prescription formulary lists.
  • If you go to the doctor often or need regular prescriptions, a gold or platinum plan may be a good option to consider. While these plans cost more, the plan pays more of the cost when you utilize the benefits.
  • If you do not go to the doctors very often or take regular prescriptions, a silver or bronze plan may be a good option to consider. These plans cost less per month in premiums, but they also pay less cost when you need to utilize the benefits. So, when selecting silver or bronze, it is important to know that you will pay more out of pocket when seeking medical care than you would if you were insured on gold or platinum plans.

 

As you can see, there are a lot of things to consider when selecting the right plans to offer your group. At MNJ insurance solutions, we are here to help you evaluate the various plans, networks, and options to meet your needs and budget.

 

Please contact us at 714-716-4303 if you would like more information.

 

This content is provided for informational purposes only.  While we have attempted to provide current, accurate and clearly expressed information, this information is provided “as is” and MNJ Insurance Solutions makes no representations or warranties regarding its accuracy  and completeness.  The information provided should not be construed as legal or tax advice or as a recommendation of any kind.  External users should seek professional advice form their own attorneys and tax and benefit plan advisers with respect to their individual circumstances and needs.

Suggested Reading for Patient Protection and Affordable Care Act (“PPACA”)

Posted by mnjinsurance on July 29, 2015

Often times, we receive requests from our clients and HR professionals wanting to learn more details on PPACA and thought we would share some good resources we have found.  We hope this helps!

 

Good Books:

 

  • ObamaCare Survival Guide – by Nick J. Tate
  • Health Care Reform Simplified – What Professionals in Medicine, Government, Insurance, and Business Need to Know – by Dave Parks
  • Beating ObamaCare – Your Handbooks for Surviving the New Health Care Law – by Betsy McCaughey, Ph.D. (Constitutional scholar and Patient Advocate) Former Lt. Governor of New York
  •  Health Care Reform – What it is, Why it’s Necessary, How it Works – by Jonathan Gruber (This book is illustrated, and in a comic-style format)

 

WEBSITES TO VISIT

 

http://www.healthexchange.ca.gov/Pages/Default.aspx

the California Health Care Exchange

 

http://www.coveredca.com/

Covered California

 

http://en.wikipedia.org/wiki/Patient_Protection_and_Affordable_Care_Act

Wikipedia version of PPACA

 

http://www.dol.gov/ebsa/healthreform/

Department of Labor Version

 

http://www.healthcare.gov/law/

 

Each medical insurance carrier in California has information posted on their websites with information regarding health care reform.

www.aetna.com

www.anthem.com/ca

www.blueshieldca.com

www.cigna.com

www.healthnet.com

www.healthform.kff.org (Kaiser)

http://www.uhc.com/united_for_reform_resource_center.htm (UHC)

 

Other Important Websites

 

Notice to Employees of (Exchange) Coverage Options:  www.dol.gov/ebsa

Health Care Reform Individual Mandate

Posted by mnjinsurance on July 29, 2015

Under the Affordable Care Act, the individual mandate requires all citizens and legal residents of the United States to have “minimum essential coverage” insurance b y January 1, 2014.  People who do not have qualified health insurance or government health plan, like Medicare or Medicaid, must obtain health insurance or pay a penalty tax called the “shared responsibility payment.”

 

People have “minimum essential coverage” if they have:

  • Government-sponsored plan (i.e. Medicare, Medi-Cal)
  • Employer-sponsored plan
  • Individual plan

 

U.S.-issued expatriate plans provide minimum essential coverage for expatriate employees and their dependents regardless of where they are located in the world.

 

People can choose to buy health insurance “on-exchange” or “off-exchange” plans that open in 2014.  Some people can also receive federal premium assistance on an exchange, depending on household income.  NOTE:  There is a specific Open Enrollment period for which individuals can apply for coverage on/off the exchange, and individuals can no longer enroll at any time throughout the year (as done in prior years to Health Care Reform).

 

ACA-graphic-3If a person does not have minimum essential coverage, the IRS will collect a tax penalty from him/her.  The monthly tax penalty is described as 1/12th of the greater of:

  • For 2014:  $95 per uninsured adult in the household (capped at $285 per household) or 1% of the household income over the filing threshold.
  • For 2015: $325 per uninsured adult in the household (capped at $975 per household) or 2% of the household income over the filing threshold.
  • For 2016:  $695 per uninsured adult in the household (capped at $2,085 per household) or 2.5% of the household income over the filing threshold.

 

The penalty will be half of the amount for people under age 18.  Beginning in 2017, the penalties will be increased by the cost-of-living adjustment.

 

There are a few exceptions to the penalty, including:

 

  • Religious reasons,
  • Not present in the United States,
  • In prison,
  • Not able to pay for coverage that is more than 8% of the household income,
  • An income that is below 100% of the Federal Poverty Level,
  • Having a hardship waiver, or
  • Not covered for less than three months during the year.

 

See the following sites for more details:

The Requirement to Buy Coverage Under the ACA

IRS Individual Shared Responsibility Provision

 

This content is provided for informational purposes only.  While we have attempted to provide current, accurate and clearly expressed information, this information is provided “as is” and MNJ Insurance Solutions makes no representations or warranties regarding its accuracy  and completeness.  The information provided should not be construed as legal or tax advice or as a recommendation of any kind.  External users should seek professional advice form their own attorneys and tax and benefit plan advisers with respect to their individual circumstances and needs.

What is “Affordable” Coverage under Health Care Reform?

Posted by mnjinsurance on July 29, 2015

Under the Patient Protection and Affordable Care Act, the employer-provided coverage must be “Affordable,” so that Applicable Large Employers avoid penalties under the “Pay or Play” rules.

Affordability will be determined by whether the coverage offered costs an employer more than 9.5% of their annual household income.  Since there is no practical way for an employer to know what an employee’s “household income” is, employers can use one of the following safe-harbor methods to ensure plan affordability:

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  • Form W-2:  An employee’s monthly contribution for self-only coverage is affordable if it does not exceed 9.5% of their W-2 wages (box 1) for that calendar year.
  • Rate of Pay:  An employee’s monthly contribution for self-only coverage is affordable if it is no more than 9.5% of their monthly wages (hourly rate of pay x 130 hours, or for salaried employees, their monthly salary figure).
  • Federal Poverty Line (FPL): An employees monthly contribution for self-only coverage is affordable if it does not exceed 9.5% of the PFL for a single individual.

 

If an employer does not provide a plan that is “affordable” with at least “minimum value” coverage, the employee can shop for insurance through a public exchange and may qualify for federal tax credits and/or subsidy.  Employers that qualify under the ACA “Pay or Play” employer mandate, will face penalties if they fail to provide “affordable” with at least “minimum value” coverage and have employees that receive federal tax credits when purchasing exchange-based coverage.

 

  • Starting January 1, 2015, employers with 100 or more full-time equivalent employees must offer “affordable” coverage with at least “minimum value” coverage to 70% of their full-time employees.  By 2016, large employers (100+ FTE) will need to provide coverage to at least 95% of their full-time employees under the ACA “Pay or Play” employer mandate.
  • Starting January 1, 2016, employers with 50 or more full-time equivalent employees must offer such coverage to at least 95% of their full-time employees under ACA “Pay or Play” employer mandate.

 

It is important to note that if an Employer offers a plan that is “affordable to the employee with at least “minimum value” coverage, the employee is NOT eligible to receive federal tax credits through Covered California (public exchange).  The exception to this rule is for employees whose income is below 138% of poverty in states that have expanded Medicaid (i.e. Medi-Cal in CA), even if their employer offers coverage.  Employers are not penalized for employee who receive Medicaid coverage.  The employer must meet the “affordability” criteria for the “employee only,” and at this time, there are no requirements for the employer to make spouse and/or dependent children coverage affordable.

 

Nothing is easy when it comes to the Affordable Care Act, however, our goal is to effectively help you navigate through your plan options and maintain your budget, while remaining compliant.

 

This post is a service to our clients and friends.  It is designed only to give general information on the developments of ACA. It is not intended to be a comprehensive summary of recent developments in the law, treat exhaustively the subjects covered, provide legal advice, or render a legal opinion.  MNJ Insurance Solutions are not attorneys and are not responsible for any legal advice.  To fully understand how this or any legal or compliance information affects your unique situation, you should discuss with a qualified attorney.

The YouToons Get Ready for Obamacare

Posted by mnjinsurance on July 29, 2015

I am sure you will agree that the Kaiser Family Foundation did an excellent job with this short video summary of PPACA.

Please contact us at MNJ Insurance Solutions at (714) 716-4303 if you have any questions or if you would like assistance with your health insurance needs.

Health Care Reform Timeline for Group Health Plans

Posted by mnjinsurance on July 29, 2015

Image result for picture of washington capital

The Patient Protection and Affordable Care Act (HR 3590) was signed by President Obama on March 23, 2010 and the Health Care and Education Reconciliation Act approved by Congress, signed by the President on Wednesday, March 31, 2010 is intended to expand coverage to millions of Americans. Some measures will be implemented in 2010, but many will not take effect until 2014 with some extended out to 2020. A timeline with a high-level overview is provided below.

It is important to note that many of these reforms and their effective dates are subject to the rules and regulations process both at the state and federal levels – which could alter the intended timing of implementation.

 

2010

  • Employers covered by the Fair Labor Standards Act (FLSA) must provide reasonable breaks and a private space (not a restroom) for mothers to express milk for their infants up to one year of age.  The requirement does not apply to small employers (fewer than 50 employees) if it would create undue hardship.  The requirement is effective on enactment, but enforcement will not begin until the Department of Labor issues guidance defining terms and enforcement procedures.
  • Employers who employ 200 or more employees must automatically enroll new full-time employees in group health insurance coverage.  Employers must also provide employees with an opportunity to opt out of coverage.  Clarification on the effective date of this provision is forthcoming.

Effective 90 days after enactment

  • Temporary, national high-risk pool created to provide health coverage for individuals with pre-existing medical conditions.
  • Temporary re-insurance pool created for employer-sponsored plans providing health coverage to retirees over 55, who are not eligible for Medicare.
  • Ten percent tax on indoor tanning services applied after July 1, 2010.

Effective the first plan year beginning on or after September 23, 2010

  • Dependent health care coverage extended to adult children up to age 26.
  • Denial of coverage of pre-existing conditions prohibited for children.
  • Limits on lifetime dollar value of health coverage prohibited.
  • Rescinding health care coverage prohibited, except in the case of fraud on part of beneficiary.
  • Health plans required to provide preventive care without cost sharing, including certain immunizations; preventive care for infants, children, and adolescents; and certain preventive care and screenings for women.
  • Prohibition on requiring authorization of the primary care physician before a patient can see an obstetrician or gynecologist.
  • Tax credits provided to small business (fewer than 25 employees and average salary less than $50,000) that provide employees health care coverage.  The employer must pay at least 50% of the cost of coverage to qualify.

2010: Other Effective Dates

  • $250 rebate to Medicare Part D beneficiaries who reach the “donut hole” coverage gap in 2010 ($2830 in total drug costs).  Rebates expected to begin in July.
  • Health plans required to report percentage of premium dollars spent on clinical services, quality, and other activities.  Effective January 1, 2011, health plans are to pay rebates to consumers if spending on clinical services and quality is below a target level (85% for large groups; 80% for small group and individuals plans).
  • Adoption tax credit and adoptions assistance exclusion increased by $1000, effective for taxable years after 12/31/2009.

2011:

  • Employers required to report value of employer-provided health coverage on employees’ W-2 form.
  • Grants provided to small businesses to establish wellness programs.
  • Pharmaceutical manufacturers required to provide 50% discount on brand-name drugs purchased by Medicare Part D beneficiaries within the “donut hole” gap in coverage.
  • Over-the-counter medications no longer eligible for purchase through HSA or FSA plans, unless prescribed by a physician (in order to make rules consistent for itemized deduction of medical expenses).
  • Tax on early withdrawal from HSA (before age 65 for non-medical expenses) increased from 10 to 20 percent.
  • Long-term insurance program, finalized by voluntary payroll deductions, created to provide benefits to adults who become disabled.

2013:

  • $2,500 cap set on health care FSA contributions (may increase in subsequent years to keep pace with increases in the Consumer Price Index).
  • Deduction eliminated for employers who receive Medicare Part D retiree drug subsidy payments.
  • Begin phase-in of subsidies to eliminate “donut hole” gam in Medicare Part D coverage for prescription drugs by 2020.
  • Threshold for itemized deductions for medical expenses increased from 7.5 to 10 percent.  Taxpayers over age 65 can claim itemized deductions at 7.5 percent of adjusted gross income through 2016.
  • Medicare Part A (hospital insurance) tax rate on wages increased from 1.45 to 2.35 percent on earnings over $200,000 for individual taxpayers and $250,000 for married couples filing jointly.  Tax of 3.8 percent applied to unearned income for higher-income taxpayers.
  • Excise tax of 2.3 percent of the sale of specified medical devices.

2014:

  • States required to establish health benefit exchanges to facilitate the purchase of health insurance by individuals and small groups.
  • Individuals required to have minimum essential health care coverage.  Those who cannot demonstrate they have coverage will be required to pay a penalty equal to the greater of $95 or 1% of taxable income in 2014 (increasing annually).  Individuals, who cannot find a premium that is less than 8 percent of their income, or whose incomes are below the tax filing threshold are exempt.
  • Employers with 100 or more full-time equivalent “FTE” employees penalized for not providing health coverage (if employees without coverage are eligible for a subsidy on insurance exchanges).  Penalty is $2,000 per employee, with first 80 employees exempt (transitional relief for 2015).
  • Employers that offer coverage and contribute to the cost of coverage are required to offer “free choice vouchers” to employees with incomes below 400 percent of the federal poverty level and for whom the employer coverage costs between 8 and 9.8 percent of the employee’s household income to purchase health plans through the exchanges.
  • Insurers must cover all individuals and employers that apply for coverage.
  • Denial of coverage for participation in clinical trials is prohibited.
  • Insurance companies are limited in charging higher rates for higher-risk beneficiaries.  Factors allowed for consideration is limited to age, geography, family size, and tobacco use.
  • Annual dollar limits on essential health coverage is prohibited.
  • All qualified health plans within an exchange and in the individual and small group markets required to offer the essential health benefits package which includes specified benefits, limites on cost-sharing, and minimum actuarial values in coverage.
  • Increased small business tax credit for health coverage provided to employees through an exchange.
  • Health Insurance Provider W-2Reporting on the value of employer-sponsored coverage form 2013 (due January 2014).
  • Temporary Reinsurance Program Fee enrollment count due November 15, 2014 ($63/covered life for 2014); Fee sunsets after 2016.
  • Deadline for certain amendments to Section 125 Cafeteria Plan Documents (December 31, 2014).

2015:

  • Individual mandate penalty is the greater of $325 per adult or 2% of taxable income.
  • Employer-shared responsibility penalty begins for employers with 100+ FTE.
  • W-2 Reporting on the value of employer-sponsored coverage for 2014 (January 2015).
  • First installment of 2014 Temporary Reinsurance Program Fee due by January 15, 2015.
  • Comparative Effectiveness Research Fee “PCORI” continues (return/fees due by July 31, 2015).
  • Temporary Reinsurance Program Fee enrollment count due by November 15, 2015 ($44/covered life for 2015).
  • Second installment of 2015 Temporary Reinsurance Program Fee due by November 15, 2015.

2016:

  • Individual mandate penalty is the greater of $695 or 2.5% of taxable income.
  • Employer-shared responsibility penalty begins for employers with 50+ FTE.
  • First installment of 2015 Temporary Reinsurance Program Fee due by January 15, 2016.
  • Large Employer Reporting to IRS (Section 6055) on 2015 coverage offered to full-time employees.  This includes employer reporting to employees by January 31, 2016.
  • W-2 Reporting on the value of employer-sponsored coverage for 2015 (January 2016).
  • Comparative Effective Research Program Fee/PCORI continues (return/fees due by July 31).
  • Temporary Reinsurance Program Fee enrollment count due by November 15, 2015 (final year); national per capita rate for 2016 set in 2015.
  • Second installment of 2015 Temporary Reinsurance Program Fee due by November 15, 2016.

2017:

  •  Individual mandate penalty is greater of $695 (indexed)/adult or 2.5% of taxable income.
  • Exchanges may permit large employer to purchase Exchange coverage.
  • Employer shared responsibility penalty continues.
  • First installment of 2016 Temporary Reinsurance Program Fee due by January 15, 2017.
  • W-2 Reporting on the value of employer-sponsored coverage for 2016 (January 2017).
  • Large Employer Reporting to IRS (Section 6055) on 2016 coverage offered to full-time employees.  This includes employer reporting to employees by January 31, 2017.
  • Comparative Effectiveness Research Fee/PCORI continue (return/fees due by July 31).
  • Second installment of 2016 Temporary Reinsurance Program Fee due by November 15, 2017.

2018:

  • 20% Excise Tax on health plans that cost above $10,200 (single) and $27,500 (family), indexed to the CPI-U.
  • Individual mandate and employer shared responsibility penalties continue.
  • Large employer reporting to the IRS on 2017 coverage offered to full-time employees.  This includes the employer reporting to employees by January 31, 2018.
  • W-2 Reporting on the value of employer-sponsored coverage for 2017 (January 2018).
  • Comparative Effectiveness Research Fee/PCORI continue (return/fees due by July 31).

Effective Dates to be Determined in Regulation:

  • Auto-enrollment of new hires (awaiting guidance).
  • Reporting related to transparency in coverage for non-grandfathered plans, not sooner than 2015.
  • Quality reporting (for non-grandfathered plans, awaiting guidance).
  • Nondiscrimination rules for insured plans (for non-grandfathered plans, awaiting guidance).
  • Plans certify compliance with HIPAA EDI standards and operating rules (proposed deadline: December 31, 2015).

 

Disclaimer:  This document is for general information purposes only.  While we have attempted to provide current, accurate and clearly expressed information, this information is provided “as is” and we make no representations or warranties regarding its accuracy or completeness.  PPACA provides are subject to change.

The information provided should not be construed as legal or tax advice or as a recommendation of any kind.  External users should see professional advice from their own attorneys and tax and benefit plan advisers with respect to their individual circumstances and needs.