Affordable Care Act: Updates and Areas of Concern for Employers in 2014

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1 Affordable Care Act: Updates and Areas of Concern for Employers in 2014 Cerebral Palsy Association of NYS October 22,2013 Dan Colacino

2 Non-Discrimination Rules For Non-Grandfathered Insured Plans Non-discrimination Rules: Fully Insured Non-Grandfathered Plans Differences from 105h rules 1. Applies only to group health plans so excludes retiree plans, excepted benefit plans 2. Penalties apply to employer including excise tax and potential civil actions; Excise tax is $100 per day with respect to EACH individual discriminated against Make sure you look at your contribution and eligibility policies

3 Section 125 Non Discrimination Under Section 125, a cafeteria plan must satisfy three separate nondiscrimination tests. A cafeteria plan must not discriminate in favor of: HCIs as to eligibility to participate (eligibility test); HCIs as to contributions and benefits (contributions and benefits test); and Key employees as to concentration of benefits (key employee concentration test). For purposes of the above three tests, an HCI is defined as: A more-than-5-percent shareholder; Any officer; or An individual with annual compensation greater than $115,000 (for 2013).

4 IRS Guidance on Tax Treatment of Same Sex Marriages Guidance issued on August 29,2013 (Revenue Ruling ) Individuals of the same sex will be considered to be lawfully married under IRS Code as long as they were married in a state whose laws authorize the marriage even if they are domiciled in a state that does not recognize the validity of same sex marriages. The ruling does not include civil unions, domestic partnerships or other similar formal relationships not denominated as marriage under the laws of that state Ruling applies as of September 16,2013 IRS has noted that taxpayers may rely on this advice for filing amended or adjusted returns to claim credits or refunds

5 Impact of DOMA on Flex, HRA s, etc. Further guidance expected from DOL and Treasury on effective dates of plan changes Options so far in the market; Allowing retroactive changes back to June 26, the original date of the ruling Considering this a qualifying event and allowing enrollment into 125 plans Waiting for further guidance

6 SBC Safe harbors The Departments have adopted the following additional safe harbor. SBCs may be provided electronically to participants and beneficiaries in connection with their online enrollment or online renewal of coverage under the plan. SBCs also may be provided electronically to participants and beneficiaries who request an SBC online. In either case, the individual must have the option to receive a paper copy upon request.

7 Notice to Employees of the Marketplace Temporary guidance was issued on May 8 th 2013 but employers can rely on this for 2014 No penalty for non-compliance (DOL FAQ 9/12/2013) Electronic distribution follows regular DOL guidelines All new employees get the notice within 14 days of hire Current employees must get the notice prior to 10/1/2013

8 HIPAA Notice of Creditable Coverage Rules for providing certificates of creditable coverage have been superseded by the prohibition pre-existing conditions This amendment goes into effect on 12/31/2014 No HIPAA certs required after this date

9 Health Reimbursement Accounts Flexible Spending Accounts: Application to Affordable Care Act Both are considered group health plans Therefore, they need to comply* with all ACA regulations such as: PCORI fee Reinsurance Fee Annual limits Lifetime limits * Some are exempt

10 Flexible Spending Accounts: Application to Affordable Care Act FSA s don t have to comply if they only provide excepted benefits (e.g. dental, vision) FSA s are considered to provide excepted benefits only if: Other group health plan coverage is made available by the employer The plan is structured so that the maximum amount payable is not more than 2 times the ee contribution or $500 plus the ee contribution, whichever is greater

11 Health Reimbursement Accounts: Application to Affordable Care Act HRA s usually have an annual limit which would preclude them after 1/1/2014. Those HRA s which are integrated with an employer sponsored plan (which has no annual limit) can continue beyond 1/1/2014 The employer can allow an HRA to be integrated with another employer sponsored plan, if they wish, such as a spouse s plan

12 Health Reimbursement Accounts Flexible Spending Accounts: Application to Affordable Care Act Some standalone HRA s may continue beyond 1/1/2014 provided they are: HRA s which cover dental and vision expenses only HRA s which exist to runout amounts contributed prior to January 1,2014

13 Employer Shared Responsibility Requirement Delay

14 Employer Shared Responsibility Requirement Penalties and Reporting requirements delayed until January 1, 2015 (Notice , IRB 116) All other requirements are effective for plan years beginning on or after January 1, 2014

15 Reporting and Penalties Delayed Required employer and carrier reports originally due in 2015 have been put off until 2016 Penalties, based on these reports, have also been postponed until 2016

16 Impact of the Delay in Employer Shared Responsibility Requirements* Approximately 0.4% of firms will pay a penalty for not offering health insurance (represents 1.6% of all workers) 1.1% of firms will pay some penalty for not offering affordable coverage ( a total of < 1% of the workforce) The one year delay will cost the Federal Gov t approximately $11 billion dollars in lost revenue. *Rand Corporation 2013 Study Delaying the Employer Mandate

17 Rules for complying with Employer Reporting Requirements Two sections of the Code: 6056: Applicable Large Employer (ALE), >50 FTE s 6055: Any entity providing MEC to an individual which are generally insurance carriers and self-funded employers

18 Rules for complying with Employer Reporting Requirements Section 6056 requires employers to; Report to IRS information about the health care coverage they have offered their employees by 2/28 or 3/31 if filed electronically Requires employers to furnish related statements to employees so they can determine how to file their tax return by 1/31 each year

19 Rules for complying with Employer Reporting Requirements 6056 required information includes Employer identification number Certification as to whether the employer offers its full time employees and their dependents MEC Length of the waiting period Months during the year when the coverage was available Monthly premium for the lowest cost plan in all tiers Employer share of the premium Number of FT employees each month Name, address, SS# of each FT employee and months they were covered

20 Proposed Rules for complying with Employer Reporting Requirements Employers subject to both 6056 IRS is considering minimizing the required information Using the W-2 to provide employee information instead of a separate form Employers subject to both 6056 and 6055 Considering an option to report only 6055 and the W-2 instead of providing two employee statements

21 New Compliance Dates First forms (6055 and 6056) are due by 3/1/2016 if paper or 3/31/2016 if electronic First employee statements are due 2/1/2016 No change in dates for non-calendar year employers When final rule is published, employers will be urged to voluntarily comply for CY 2014

22 Employer Shared Responsibility Requirement Although Penalties and Reporting requirements are delayed until January 1, 2015: All other requirements are effective for plan years beginning on or after January 1, 2014 This applies to all employers with at least 50 Full Time Equivalent Employees (Applicable Large Employers)

23 Example of an Applicable Large Employer calculation 30 FT employees in each month working at least 30 hours per week 20 PT Employees in each month January; 1,575 hours worked by the 20 PT employees Divide by 120 Equals FTE s Adding in 30 FT, January had FTE s Same calculation each month for balance of the year Add up the months, divide by 12 to determine if the employer exceeds 50 Seasonal workers are included with a limited exception; if seasonal workers cause the employer to exceed 50 employees annually and they worked for 4 or fewer months, those seasonal workers can be excluded

24 Determination of Applicable Large Employer Status Applicable Large Employers are those subject to assessable penalties Defined as an employer that employed an average of at least 50 Full Time Equivalent employees on business days during the preceding calendar year Multiple companies treated as a single employer as defined by IRC Section 414

25 Employer Shared Responsibility Incentives: Potential Areas of Concern Three Scenarios 1. Employer does not offer coverage to substantially all full time employees and dependents 2. Employer offers coverage which does not meet minimum value 3. Employer offers coverage which meets minimum value but is not affordable

26 Employer Shared Responsibility Incentives: Potential Areas of Concern Scenario #1 If the Employer does not offer Minimum Essential Coverage to substantially all of their FT employees and dependents Substantially all is defined as 95% or more Determine if variable hour employees can tip the percentage below 95% If the employer is in the 50 FTE range, be careful about not offering coverage

27 Employer Shared Responsibility Incentives: Potential Areas of Concern Scenario #2 If the Employer provides Minimum Essential Coverage to substantially all full time employees and dependents which does not provide Minimum Value Minimum Value can be calculated on the HHS website (or by me) Shouldn t be a difficult hurdle with OOP maximum at $6,350

28 Employer Shared Responsibility Incentives: Potential Areas of Concern Scenario #3 If the Employer provides Minimum Essential Coverage to substantially all full time employees and dependents which does provide Minimum Value but is not affordable Pay or play calculators are available to run estimates. Some payroll companies will do this as well Some are expensive but they don t need to be

29 Determining Full-Time Status for Ongoing Employees Employee who works an average of > 30 hours per week Administrative period 1 st Measurement period 12 months 3 months Stability period Employee is considered FT 2 nd Measurement period 10/1/2014 9/30/2015 1/1/ /31/2016 9/30/2016

30 Determining Full-Time Status for Variable Hour or Seasonal Employees Administrative period If determined FT during Std. measurement period Initial Measurement Period 12 months 53 Days Stability period 12 months? 10/1/2014 4/30/2015 3/9/2014 Initial Hire Date 1 st standard measurement period after date of hire 3/8/2015 Anniv. Date of hire 5/1/2015 9/30/2015 End of 1 st standard measurement period 4/30/ /31/2016

31 Rose & Kiernan, Inc. Hire/Rehire Rule If an employee is terminated and rehired within 26 weeks, the employer may not treat them as a new hire when they return to work Hours of service prior to the termination are taken into account for purposes of determining whether the employee is treated as a full time employee For example, if the employee was treated as full time employee prior to termination, the employee is still considered full time until the end of the stability period

32 Rose & Kiernan, Inc. Special Periods of Unpaid Leave Rule Refers to counting hours during unpaid leave due to: Family and Medical Leave Act (FMLA) Uniformed Services Employment and Reemployment Rights Act (USERRA) Jury Duty

33 How to deal with breaks in employment for employees on special unpaid leave Employee works an average of 35 hours per week Returns to work Break in service Period of employment 38 weeks 12 weeks 2 week s Stability period Measurement period Hire date Leaves on FMLA End of measurement period Employee is credited with an average of 35 hours per week

34 Two Key Benefit Plan Provisions Beginning in Day maximum on Waiting Periods 90 day rule applies to anyone after your 2014 plan year date, not just those who are hired after the renewal date *Cost Sharing/Out-Of-Pocket Maximums $6350/$12,700 Note: out of pocket maximum includes all copays Plans with multiple vendors can have separate maximums for 2014 only

35 Enforcement As stated in previous FAQs,(3) the Departments basic approach to ACA implementation is: [to work] together with employers, issuers, States, providers and other stakeholders to help them come into compliance with the new law and [to work] with families and individuals to help them understand the new law and benefit from it, as intended. Compliance assistance is a high priority for the Departments. Our approach to implementation is and will continue to be marked by an emphasis on assisting (rather than imposing penalties on) plans, issuers and others that are working diligently and in good faith to understand and come into compliance with the new law. Accordingly, consistent with this guidance, during this first year of applicability, the Departments will not impose penalties on plans and issuers that are working diligently and in good faith to comply.

36 Dan Colacino Rose and Kiernan, Inc

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