Cadillac Tax - 40% of excess, effective January 1, 2018 for plan
States can allow larger employers to join exchange plans
IRS Forms 1095-C and 1094-C for ACA Reporting Section 6056 for Calendar Year 2015
- Reporting 2015 employee and dependent enrollment results to employees by January 31, 2016 and,
- To the IRS by March 31, 2016 (electronic filing due date)
Written Notice to Employees about State Exchanges and Federal Subsidies
- Notice beginning March 1, 2013
IRS Forms 1095-C and 1094-C for ACA Reporting Section 6056 for Calendar Year 2015
- Required for reporting 2015 employee and dependent enrollment results to employees by January 31, 2016 and to the IRS by March 31, 2016 (electronic filing due date)
- Confirm responsibility for reporting and filing both internally and with payroll vendor and insurance companies
Comparative Effectiveness (PCORI) Annual Fee, $2.08 per participant in 2014
- Included in premium in fully insured plans, payable by employer for HRA plan
Individual Insurance Requirement
- Requires U.S. citizens and legal residents to have qualifying health
State Insurance Exchange Access
- State Health Insurance access to individuals and small businesses with up to 100 (50 in California) employees can purchase qualified coverage
Written Notice to Employees about State Exchanges and Federal Subsidies
- Notice beginning March 1, 2013
Employer Minimum Plan Offerings and Limits
- Bans waiting periods for employees greater than 90 days
- Prohibits annual limits on the dollar value of coverage
- Deductibles to new plans cannot exceed $2,000 single and $4,000 family coverage (small group)
- Bans all pre-existing conditions exclusions for all individuals
- Confirm no annual limits on the dollar value of coverage
- Confirm essential health benefits
- Limit annual cost-sharing to $5,950/individual and $11,900/family
- Confirm plan design options:
- Assessed fee of $2,000 per full-time employee, excluding the first 30 employees, on employers with more than 50 employees that do not offer coverage and have at least one full-time employee who receives a premium tax credit
- Employers with more than 50 employees that offer coverage but have at least one full-time employee receiving a premium tax credit, will pay the lesser of $3,000 for each employee receiving a premium credit or $2,000 for each full-time employee, excluding the first 30 employees
- Wellness program – Can offer employees rewards of up to 30%, of the cost of coverage to participate in a wellness plan
Comparative Effectiveness (PCORI) Annual Fee, $2 per participant in 2014
- Included in premium in fully insured plans, payable by employer for HRA plan
Additional Hospital Insurance Tax of 0.9%, New Medicare Taxes of an additional 3.9% on unearned income for high income individuals ($200,000 individual, $250,000 joint)
- Send notification to affected employees before January 1, 2013
Written Notice to Employees about State Exchanges and Federal Subsidies
- Notice beginning March 1, 2013
Comparative Effectiveness (PCORI) Annual Fee, $1 per participant in 2013
- Included in premium in fully insured plans, payable by employer for HRA plan
Form W-2 — Information about the Total Cost of Health Care
- Health coverage treated as applicable employer-sponsored coverage without regard to whether the employer or the employee pays for the coverage
- Fewer than 250 W-2 Forms in 2011 are not required to report the value of employer-provided health care for 2012
- Determine method of calculation of cost:
- COBRA applicable premium method
- Modified COBRA premium method
- Premium charged method (insured plans only)
- Coordinate with Payroll system
Summary of Benefits and Coverage (SBC)
- Due Date — first day of the first open enrollment period on or after September 23, 2012
- For new enrollees — first day of the first plan year on or after September 23, 2012
- Confirm insurance company delivers SBCs 30 days before the open enrollment
FSA Limitation
- Amend the FSA Plan Documents to a maximum of $2,500 for any taxable year beginning after December 31, 2012
- Communication to employees before January 1, 2013
