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1 Heffernan Benefit Advisors Presents Health Care Reform: What Non-Profits Need to Know The session will begin shortly Sound should come through your speakers when the session begins Verify that the volume is turned up on your computer You can listen through your computer or over the phone If there is no sound on your computer or you would like to call in directly, use the following information: Session phone number: (877) Access code:

2 Health Care Reform: What Non- Profits Need to Know October 2014 Presented by Erica Storm, Esq., Becca Kopps, Esq. and Brian Conner, HIB

3 Introduction

4 About the Presenters Erica Storm, Esq. Becca Kopps, Esq. Employment and benefits attorneys Expertise in health care reform and health plan issues Educate companies on compliance obligations and provide compliance resources Brian Conner, HIB Chief Operations Officer, Benefits Advisory Services 20 years experience in Global Human Resources and Operations Leader of service and benefits technology platforms

5 Webinar Logistics To call in to connect to audio: Phone number: Access code: We welcome your questions at any time! Questions will be addressed at the end of the session. Select Q&A and choose Send to All Panelists to submit your questions.

6 Health Insurance Exchanges

7 Exchange Open Enrollment

8 Important Dates Nov. 15, 2014 Individual Exchange Open Enrollment begins for 2015 coverage Dec. 15, 2014 Last day to enroll for coverage that begins Jan. 1, 2015 Jan. 1, 2015 February 15, 2015 The date 2015 coverage can start if individual applies by Dec. 15, 2014 or accepts automatic enrollment The last day to enroll in 2015 coverage (unless a special enrollment period is available)

9 Exchange Subsidies and Tax Credits Employees who are not offered coverage Not eligible for government programs (like Medicaid) Meet income requirements (less than 400% of FPL) Employees who are offered coverage Not eligible for government programs (like Medicaid) Meet income requirements (less than 400% of FPL) Not enrolled in employer s plan Employer s coverage is unaffordable (greater than 9.56% of income for single coverage) or not of minimum value (covers less than 60% of cost of benefits)

10 Court Rulings on Subsidies Lawsuits challenged subsidies provided through federal Exchanges Conflicting court rulings DC Circuit: subsidies invalid in states with FFEs 4th Circuit: subsidies available in all states Subsidies continue to be available in all states for now Further court review expected

11 Cafeteria Plan Elections

12 IRS Expands Election Change Rules Cafeteria plan elections are irrevocable for coverage period UNLESS an exception applies IRS Notice Issued on Sept. 18, 2014 Expands permissible changes to health coverage elections under Section 125 cafeteria plans Adds additional exceptions to rule that cafeteria plan elections are irrevocable for coverage period Guidance is effective immediately

13 Election Change Situations A cafeteria plan can be amended to permit prospective election changes in two additional situations Pay or Play Rules Employee s hours of service are reduced but employee is still eligible for health plan coverage To change cafeteria plan election, employee must enroll in another plan that provides minimum essential coverage Exchange Enrollment Employee is covered under employer s non-calendar year plan and would like to switch to Exchange coverage To change cafeteria plan election, employee must enroll in Exchange coverage

14 Plan Amendments Cafeteria plan document must be amended if employer wants to allow the new permitted election changes The amendment must be adopted by the end of the plan year in which the elections are allowed The amendment may be effective retroactively to the beginning of that plan year if: The plan is operated in accordance with Notice and The employer informs participants of the amendment Amendments for the 2014 plan year may be adopted at any time on or before the last day of the 2015 plan year

15 Employer Payment Plans

16 Paying for Employee s Individual Coverage on a Pre-Tax Basis IRS has restricted employer payment plans that reimburse employees for any individual health insurance premiums on a pre-tax basis Cannot be integrated with individual market coverage, so will not comply with ACA market reforms Penalties for violating market reform rules are $100/day per violation ($36,500/year per employee)

17 IRS Guidance on Reimbursing Individual Health Insurance Premiums IRS Notice Sept. 13, 2013 Introduced employer payment plans concept Group health plans subject to ACA s preventive care and annual limit rules FAQs May 13, 2014 Clarified application of excise tax penalty to employer payment plans May reimburse premiums on an after-tax basis

18 Employer Shared Responsibility Rules: Pay or Play

19 Employer Shared Responsibility Rules Effective Jan. 1, 2015 Applicable Large Employer: includes non-profit and government entities Penalties may apply: Coverage must be offered to: Penalties triggered when: Applicable Large Employer does not offer coverage Applicable Large Employer offers coverage but coverage is unaffordable or does not provide minimum value Full-time employees and dependents (children) Any FT employee gets a subsidy for coverage through an Exchange

20 Applicable Large Employer Definition For a calendar year, an employer that employed, on average, at least 50 full-time employees during the prior calendar year Includes full-time equivalent employees Special rules for seasonal workers ALE status is locked in for each calendar year Based on hours already worked in the prior year Can use 6+ month periods for 2015 status Does not change if employee number fluctuates during the current year Commonly-owned companies treated as a single employer Determined under IRC section 414 Controlled group and affiliated service group rules Employee numbers for each member of the group aggregated

21 Full-time Employee Full-time employee Employed on average at least 30 hours of service per week (130 hours) in a calendar month Full-time equivalent employee (FTE) Hours of service for PT employees (up to 120 hours/person per month) Divide by 120 Result = number of FTE employees for the month

22 Hours of Service Exclusions Volunteer employees Student employees Members of religious orders Service outside the U.S. Hours of bona fide volunteers at governmental or tax-exempt organizations are excluded Nominal compensation permitted Hours of service for work study and unpaid interns are excluded No general exception for student employees of educational organizations or outside employers No general exception for paid interns Hours of individuals subject to vow of poverty are excluded If compensation is foreign-source income

23 One-year Delay for Medium-sized Businesses Applies to ALEs with fewer than 100 full-time employees (including FTEs) on business days during 2014 No 4980H penalties will apply during 2015 For non-calendar year plans, includes the portion of the 2015 plan year that is in 2016 Eligibility conditions apply, including certification of eligibility

24 Delay for Non-Calendar Year Plans Can delay compliance until the 2015 plan year Conditions must be met Final rules extend 2014 transition relief and expand conditions so that more employers are eligible Transition relief tests related to: Pre-2015 eligibility Significant percentage of all employees Significant percentage of full-time employees To qualify: Must have a non-calendar year plan as of Dec. 27, 2012 May not have modified the plan year after Dec. 27, 2012 to start at a later date

25 4980H(a) Penalty Employers that do not offer coverage to substantially all full-time employees (and children) Substantially All Percentage 2015: 70% of full-time employees 2016 and beyond: 95% of FT employees Penalty Amounts $2,000 x (all FT employees 30) x 1/ : Employers with 100+ EEs subtract 80

26 4980H(b) Penalty Applies to employers that offer coverage to substantially all FT employees but: Do not offer coverage to ALL FT employees Offer coverage that is unaffordable Offer coverage that does not provide minimum value Penalty amount $3,000 x each employee who gets subsidized coverage x 1/12 Penalty is capped at the amount the employer would have had to pay under section 4980H(a) IF it applied

27 Determining Full-Time Status Full-Time Employee: for any month, an employee who is employed, on average, at least 30 hours of service per week (or 130 hours per month) Two methods Employer choice Monthly measurement method Look-back measurement method May apply either monthly measurement method or look-back measurement method based on permitted categories of employment

28 Permitted Employee Categories Collectively bargained vs. non-collectively bargained Hourly vs. salaried employees Different groups of collectively bargained employees (separate CBAs) Employees whose primary places of employment are in different states

29 Look-back Measurement Method May be used for new variable hour, seasonal and part-time employees IF used for ongoing employees Generally may not use the lookback measurement method for variable hour/seasonal/part-time employees and use monthly measurement method for employees with predictable schedules Transition measurement periods allowed for 2014 Measurement Period Counting hours of service (3-12 months) Administrative Period Time for enrollment/disenrollment (Up to 90 days) Stability Period Coverage provided (or not) same length for new and ongoing employees

30 Types of Employees Ongoing employees Employed for at least one complete standard measurement period (SMP) Measure FT status during SMP New employees expected to work full-time Reasonably expected at start date to be a full-time employee (and is not seasonal) Must offer coverage by end of first 3 full calendar months of employment Measure as an ongoing employee once employed for a full SMP

31 Types of Employees New variable hour employees Employer cannot determine whether the employee is reasonably expected to be employed on average at least 30 hours of service per week during the initial measurement period (IMP) New seasonal employees Hired into a position for which the customary annual employment is 6 months or less New part-time employee Reasonably expected to be employed on average less than 30 hours of service per week during initial measurement period Measure for full-time status in Initial Measurement Period and then measure as ongoing employee in next Standard Measurement Period

32 Look-Back Measurement Method Example 2013 Nov. 1, 2013 Dec 31, 2013 Measurement Period 2014 Jan 1, 2014 Nov. 1, 2014 Dec 31, 2014 Measurement Period cont. Admin Period 2015 Jan 1, 2015 Dec 31, 2015 Stability Period

33 Transition Measurement Period for Ongoing Employees Jan 1, 2014 April 1 Nov. 1 Dec 31 Transition SMP Admin Period Jan 1, 2015 Dec 31 Stability Period

34 Employer Reporting

35 Section 6055 and 6056 Reporting Reporting rules apply to: Providers of minimum essential coverage (6055) Applicable large employers (6056) Note: self-funded plan sponsors that are ALEs must report under both sections, but report on a single form Reporting entities are required to: File information returns with the IRS Provide statements to either full-time employees (6056) or covered individuals (6055)

36 Purpose of Reporting IRS: Administer the employer shared responsibility provisions of Section 4980H (the pay or play rules) Administer the individual shared responsibility provision (the individual mandate) IRS and individuals: Help determine whether an employee is eligible for a premium tax credit for Exchange coverage Show compliance with the individual mandate (prove that they do not have to pay a penalty)

37 IRS Reporting Guidance March 5, 2014 July 24, 2014 Aug. 28, 2014 Aug. 29, 2014 Final regulations on 6055 and 6056 reporting requirements Draft versions of forms that will be used for reporting Draft instructions for completing forms and reporting process IRS Q&As on information reporting requirements

38 Deadlines Rules effective for 2015 coverage (2016 reporting) General rules: Individual statements due by Jan. 31 of the following year IRS returns due by Feb. 28 of the following year (March 31 if filed electronically) 2016 dates: Employee statements: Feb. 1, 2016 IRS returns: Feb. 29, 2016 (or March 31 for electronic filing)

39 Section 6055: Required Returns Form 1094-B: Transmittal of Health Coverage Information Return Form 1095-B: Health Coverage Draft instructions are available

40 Information Reported To the IRS The provider s name, address and EIN The responsible individual s name, address and TIN (or date of birth if a TIN is not available) The name and TIN (or date of birth if a TIN is not available) of each covered individual and the months he or she was enrolled For coverage provided by an issuer through a group health plan, the name, address and EIN of the employer sponsoring the plan and whether coverage is a SHOP QHP and the SHOP s identifier To the Individual A written statement including: The information reported to the IRS for the covered individual(s) A phone number for the provider s contact person

41 Section 6056: Required Returns Form 1094-C: Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Return Form 1095-C: Employer-Provided Health Insurance Offer and Coverage Draft instructions are available

42 6056 Methods of Reporting General method: may be used by all ALEs for reporting to the IRS and furnishing statements to full-time employees Alternative methods: may be used by eligible ALEs for certain employees ALEs that are not eligible to use an alternative reporting method for certain employees must use the general method for those employees

43 6056 General Method Information Reported to the IRS ALEs must report information about health coverage offered to full-time employees, including whether an offer of health coverage was made Applies to all ALEs, regardless of whether they offered health coverage to all, none or some of their full-time employees For each full-time employee, regardless of whether coverage was offered to the employee or not, the ALE must report: Whether an offer of health coverage was or was not made to the employee AND If an offer was made, the required information about the offer Thus, even if an ALE does not offer coverage to any full-time employees, it must file returns with the IRS and furnish statements to each full-time employee to report information specifying that coverage was not offered

44 6056 General Method Information Reported to the IRS Employer name, address and EIN Contact person s name and telephone number The calendar year for which the information is reported Whether MEC was offered to full-time employees (and their dependents) each month Each full-time employee s share of the lowest cost monthly premium for self-only coverage providing minimum value The number of full-time employees for each month The name, address and TIN of each full-time employee and the months the employee was covered under the employer-sponsored plan

45 Contraceptive Mandate

46 Contraceptive Coverage Mandate Non-grandfathered plans must cover preventive care services with no cost-sharing Prevent care guidelines for women include contraceptive coverage Religious organizations exempt June 2014: Supreme Court provided narrow exception for private businesses July 2014: Supreme Court granted injunction from selfcertification requirement to a private college

47 Employers Ceasing Contraceptive Coverage July 17, 2014 Agencies issued FAQ guidance for employers planning to discontinue coverage as permitted by Supreme Court ruling Notice Requirements Ceasing coverage mid-year triggers notice requirements to participants and beneficiaries for ERISA plans Describe limitation in SPD Provide disclosure of reduction with 60 days of adoption

48 Religious Accommodations Expanded Aug. 27, 2014 Two separate rules published in response to Supreme Court decisions Address both nonprofit and closely held for-profit entities Interim Final Rule Maintains existing accommodation for certain religious nonprofit organizations that are not exempt from the mandate Creates an additional way for eligible organizations to provide notice of their objection to covering contraceptive services Organizations can notify HHS or provide self-certification to TPA or insurer Proposed Rule Would extend accommodation that is available to nonprofit religious organizations to certain closely held for-profit companies Closely-held for profit companies defined as not publicly-traded with limited owners

49 Looking Ahead

50 Nondiscrimination Rules for Fully Insured Health Plans ACA: Nondiscrimination rules: 2010: Non-grandfathered fully insured health plans must comply with nondiscrimination rules Similar to rules for self-funded plans Prohibit discrimination in favor of highlycompensated individuals IRS delayed rules indefinitely, pending issuance of regulations 2014: IRS confirmed that rules will not be enforced this year due to prior delay

51 Cadillac Tax 40% excise tax On high-cost group health coverage Applies to excess benefit of each employee s aggregate employersponsored coverage over annual limitation Annual limitation for employees: $10,200 for single coverage $27,500 for family coverage Higher limits for retirees and high-risk professions Applies for taxable years beginning in 2018 Employers must calculate and report tax Coverage provider must pay tax

52 Questions?

53 For additional help please: call and ask for a Benefits Advisor or visit Thank you!

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