ACTION PLAN

This action plan lists government regulations by the year they need to be implemented.

  • Comparative Effectiveness Research Fee: This Federal tax stops.

This action plan lists government regulations by the year they need to be implemented.

  • Cadillac Excise Tax: If the annual value of benefits exceeds $10,200 (employee only) or $27,500 (family), then the value of any benefits over these amounts (indexed for inflation) will be subject to a 40% excise tax.
  • Aggregate Value: The aggregate value cannot exceed $10,200 for single and $27,500 for family.
  • Health Care Cost Adjustments: If health care costs increase more than expected, the initial threshold will automatically adjust upward.

This action plan lists government regulations by the year they need to be implemented.

  • State Health Exchange: States may allow large employers to participate in the Exchanges.

This action plan lists government regulations by the year they need to be implemented.

  • Electronic Transaction Standards: Employers will need to comply with newly adopted operating rules and standards for electronic transactions affecting health claims, enrollment, disenrollment, premium payments and referral certifications.
  • The filing 2015 forms 1094-C and 1095-C.

This action plan lists government regulations needed to be implemented.

  • Employer Mandate: This applies to groups of 50 or more employees. If the group has at least one full-time employee receiving a premium tax credit due to the coverage being “unaffordable” or not “qualified,” the employer will pay the lesser of $3,000 per full-time employee receiving the premium tax credit or $2,000 for each full-time employee. This latter penalty applies if the employer does not provide coverage.
  • The collection of employee status and coverage information for IRS forms 1094 and 1095C filings.

This action plan lists government regulations needed to be implemented.

  • Provider Discrimination: Benefit plans cannot discriminate against a provider who is acting within the scope of their license. This applies to non-grandfathered plans only and is subject to clarifications outlined in the published interim regulations.
  • Deductibles: The annual deductible for small group plans cannot exceed $2000 per individual and $4000 per family.
  • Cost-sharing Limitations: Out-of-pocket maximums may no longer exceed the applicable limits for high deductible plans. This applies to non-grandfathered plans only and is subject to clarifications outlined in the published interim regulations.
  • Clinical Trials: Clinical trials must be covered. This applies to non-grandfathered plans only and is subject to the clarifications outlined in the published interim regulations.
  • Comparative Effectiveness Research Fee: This Federal tax is increased to $2 due to inflation. This $2 is per year per participant, which includes employees and dependents.
  • Wellness Incentives: The maximum wellness incentive increases from 20% to 30%. This may be increased to 50% subject to HHS, DOL & IRS approval.
  • No Pre-Existing Condition Limitations: This is implemented for all persons regardless of age in 2014.
  • Maximum Waiting Period: Waiting periods may not exceed 90 days. At a minimum, we will need to make coverage available the first of the month following 60 days employment or 90 days after date of hire.
  • Annual Dollar Limits: All annual dollar limits are no longer allowed.
  • Definition of Full-time Employee: Anyone who works, with respect to any month, an average of 30 hours or more a week.
  • Nondeductible Income Tax Assessment: There will be an assessment on the employer if at least one employee declines coverage. If an employee is eligible for premium assistance in a state Exchange (this applies when the wage is less than 400% of the federal poverty level….currently $43,588 for individuals and $89,400 for a family of four) and their premium cost share of the plan exceeds 9.5% of their household income, then the employer will incur a monthly penalty which is the lesser of:
    • $3,000 divided by 12, for each employee receiving the premium assistance, or
    • $2,000 divided by 12, for all full-time employees eligible for coverage.
  • Electronic Transaction Standards: Employers will need to comply with newly adopted operating rules and standards for the electronic funds transfers and health care payment and remittances.
  • Auto Enrollment: The health plan will automatically enroll employees once they become eligible. Employees can opt out if they so choose.