Benefits Buzz – September 2014

There were several important items to be aware of in the past several weeks related to employer sponsored health insurance.  Included in this month’s Benefits Buzz are summaries on:

All of these will affect employers, employees, and the insurance plans.

Benefits Buzz September 2014

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2015 Health Care Reform Compliance Checklist

As we all continue planning for the 2015 plan year, it is important to know what you need to do to stay in compliance with the Affordable Care Act.  This health care reform compliance checklist can help you do just that.

Included in the document below is information on:

  • Grandfathered plan status
  • 2015 cost-sharing limits
  • Flexible Spending Account contributions
  • Reinsurance fees
  • HIPAA certification
  • Employer penalty rules
  • What establishes a company as a large employer
  • Determining your large employer status
  • What allowances are given to medium-sized employers
  • Transition relief for non-calendar year plans
  • Monthly measurement period guidelines
  • Look-back measurement period guidelines
  • Affordability of coverage (the 9.5% rule)
  • Minimum value plans
  • Reporting of coverage

As you can tell, there is a lot to get ready for.  You do not want to be on the outside looking in on these things, so make sure you are in compliance.  While there are a lot of rules to consider, they all can be managed.

If you would like to discuss further, feel free to contact us.

Health Care Reform 2015 Compliance Checklist

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When to Begin Tracking Employee Hours for Affordable Care Act Purposes

One of the most common questions we get is related to tracking employee hours for health insurance eligibility under the Affordable Care Act.  When to begin tracking the hours and how long to track them are important things to consider when determining whether your employees are considered full-time.

Back in February, the IRS published final regulations on the employer shared responsibility rules (another post in this subject can be found here).  The brief linked below details more information, such as:

  • Which companies must track employee hours (do small employers have to track hours?)
  • How to identify full-time employees
  • What is the Monthly Measurement Method
  • What is the Look-back Measurement Method
  • When to begin tracking employee hours for both calendar year plans, and non-calendar year plans

Getting the measurement period correct is crucial to making sure you are offering benefits to the right people, which will keep you out of trouble.

Contact us if you would like to discuss further.

Pay or Play Penalty – When to Begin Tracking Employee Hours

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Supreme Court Hears Religious Challenge to Contraceptive Coverage Mandate

On March 25, 2014, the U.S. Supreme Court heard arguments in two related cases challenging the Affordable Care Act’s contraceptive coverage mandate. In these cases, for-profit businesses argue that they should be exempt from the contraceptive coverage mandate based on their religious beliefs. This Health Care Reform Compliance Bulletin summarizes the legal challenge to the contraceptive coverage mandate and what it means for other employers.

Supreme Court Hears Religious Challenge to Contraceptive Coverage Mandate

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What is a Health Plan’s Plan Year?

The term “plan year” can be confusing for some, but in the age of the Patient Protection and Affordable Care Act, it is more important than ever to have a clear understanding of what your plan year is.  So, what is a health plan’s plan year?

The first thing that should be used to determine the plan year is the summary plan description, or SPD.  For employers that file a Form 5500, the plan year is disclosed on the form.  Outside of those 2 things, federal regulations provide the following guidance on determining a health plan’s plan year:

  • The plan year is the deductible or limit year used under the plan;
  • If the plan does not impose deductibles or limits on a yearly basis, the plan year is the policy year;
  • If the plan does not impose deductibles or limits on a yearly basis, and either the plan is not insured or the insurance policy is not renewed on an annual basis, the plan year is the employer’s taxable year; or
  • In any other case, the plan year is the calendar year.

To understand the importance of a health plan’s plan year, consider the following sampling of compliance requirements linked to the plan year (and many linked to the ACA).

  • Wellness programs
  • Annual plan limits
  • Pre-existing condition prohibition
  • Non-discrimination based on health status
  • Waiting period definition
  • Cost sharing limitations
  • Disclosure and reporting requirements

For a full list of compliance requirements linked to a health plan’s plan year, and to learn more about determining the plan year, take a look at the following attachment.

What is a Health Plan’s Plan Year?

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