Affordable Care Act Employer Planning Guide

Transcription

1 Out-of-Pocket Maximums All Maximums are indexed for 2016 Single: $6,850 Family: $13,700 te that QHDHPs have a different indexing schedule: Single QHDHP: $6,550 Family QHDHP: $13,100 Jan 1, Out-of-Pocket Maximums All HSA The individual OOP max will apply to each individual enrolled in family coverage. Cannot have an aggregate OOP max for family coverage that is greater than single OOP max For 2016 plan years, no individual is required to pay more than $6,450 when on a family plan. Jan 1, Health Savings Accounts Contributions All HSA Contribution limits indexed for 2016 Single: $3,350 Family: $6,750 Must be enrolled in a qualified high deductible health plan. January 1, 2016 Employer Reporting of Health Insurance Coverage All New reporting requirement to IRS for large and self-funded employers: Name, address, and SSN of the primary insured Dates covered Eligibility Statement to participants with similar information also required. Form 1095 B: insurance companies and under 50 selffunded employers. Form 1095 C: employers with 50+ FTEs, self-funded employers complete Part III January 1, 2016 File with IRS by May 31, 2016 (Jun 30, 2016 if filing electronically) Statements to employees by March 31, 2016 Employer Shared Responsibility Rules All 50+ Applies to employers or control groups with 50+or more full time employee equivalents (FTEs). Penalties imposed if employer does not offer coverage that is "affordable" and provides minimum value. (a) $180.00/mo ($2160) per FT EE (not counting first 30) if coverage not offered to 95% of FT EEs. (b) Employer pays $270/mo ($3240) per FT EE receiving subsidized coverage if coverage is unaffordable (9.66% of EE household income). January 1, 2016

2 Patient- Centered Outcomes Research Fees (PCORI Fee) All HRA Plan year ending before Oct. 1, 2015: $2.08 per participant per year, Plan year ending before Jan. 1, 2016: $2.17 per participant per year Reported on Quarterly Tax Form, 720, line 133(b) HRA with fully-insured medical pays separate fee July 31, 2016 Transitional Reinsurance Contribution Fee All TPA may pay on behalf of selffunded plans (be wary of counting methods used) Final filing! $27 in 2015, or $2.25 per member per month. Report estimated enrollment through September, IRS will then calculate the bill. Reporting due by v 15, 2016 Fee due by Jan 15, Summary of Benefits and Coverage All SBC template simplified Additional example added Delayed until 2017 Jan 1, Cadillac Tax 40% excise tax will apply to the cost of employee health coverage that exceeds $10,200 annually for single coverage, $27,500 for family coverage. Initial dollar amounts are subject to adjustment: Health cost adjustment percentage Cost-of-living adjustment Age and gender adjustment Expected Jan 1, 2018 Delayed until 2020

3 3 Ongoing Exchange tice tify employee of exchange and availability of subsidy. All employers must distribute. Must be distributed within 14 days of employee s start date. tices first distributed by October 1, 2013 Summary of Benefits and Coverage (SBC) HRA FSA n integrated HRAs & FSAs with $500+ of employer money must provide separate SBC. Distribute at all enrollment opportunities Upon request 60 days in advance of any material changes to the SBC First effective for plans renewing after Sept 23, 2012 W-2 Reporting Large Large employer reporting started for tax year 2012 (W-2s released January 2013). IRS site has guidance on plans subject to reporting. t required for groups with less than 250 W-2s in prior year, Preventive Care Services Coverage for certain preventive care services without cost-sharing. Includes prescribed contraceptives. Waived for grandfathered plans. Includes guidelines First plan year after Sept 23, Plan Design Changes FSA Health FSA capped at $2,500. Cap is on the employee deduction, not the total benefit Plan years beginning on or after Jan 1, Plan Design Changes annual dollar limits on Essential Health Benefits. pre-existing condition exclusions All cost share amounts included in out-of-pocket maximums. Out-of-pocket may not be greater that QHDHP/HSA limits. Cannot impose more than 90 day waiting period. Quantity limits are allowed. Need to remove from organ transplant benefit as well. Transition rule for plans with 2 different administrators (ie Rx) maximums are $6,350 (single) and $12,700 (family). May include 1 month Orientation Period. Jan 1, 2014.

4 4 Ongoing 2015 Plan Design Changes FSA All cost shares included in out-ofpocket max 2015 OOP max: $6,600 (singly) & $13,200 (family) Increase Health FSA Max May have separate OOPs (i.e. & Rx), but total cannot exceed the max 2015 QHDHP OOP: $6,450 (single) & $12,900 (family) 2015 max is $2550 Jan 1, 2015 New Taxes MDV icare Hospital Insurance: 0.9% for income over $200,000 ($250,000 for joint return) Health Insurance Provider Fee: 2.5% on insurance carriers (medical, dental, vision) Employers are not required to match the increase. Included in premiums January 1, 2013 January 1, 2013 Transitional Reinsurance Contribution Fee Self Health plans contribute to a reinsurance fund to offset risks in individual health insurance market. 2014: $63 PMPY, $5.25 PMPM 2015: $44 PMPY, $3.67 PMPM 2016: $27 PMPY, $2.25 PMPM Reporting due by vember 15 Payment due by January 15 Patient- Centered Outcomes Research Fees (PCORI Fee) Self HRA Ending Sept 2013: $1 PPPY Ending Sept 2014: $2 PPPY Ending Sept 2015: $2.08 PPPY Ending Sept 2016: $2.17 PPPY HRA with fully-insured medical pays separate fee July 31 (Quarterly tax filing, line 133(b)) Individual Coverage Mandate Higher of household income or tax: 2014: 1% or $95 / adult ($47.50 per child) 2015: 2% or $325 / adult ($ / child) 2016: 2.5% or $695 / adult ($ per child) 2014 max: $ max: $ max: $2, tax year 2015 tax year 2016 tax year

5 5 Ongoing Subsidies for low and middle-income individuals Individuals earning up to 400% of federal poverty level. Individuals eligible for affordable group coverage are not eligible. Must purchase coverage through Exchange. Premium for employee-only coverage must be unaffordable January 1, 2014 Wellness Incentives HIPAA limits incentives for wellness programs to 30%. 50% for tobacco related programs. See EEOC regulations Jan 1, Definition of Full- Time Employee ical Full-time employees for medical coverage defined as working an average of 30 hours per week. May employ various tracking techniques for variable hour employees. Jan 1, 2015 Employer Shared Responsibility Rules ical H(a) assessment payment: per FT EE (not counting first 30) if coverage is not offered 2014: $2,000 or $166.67/mo 2015: $2,080 or $173.33/mo 2016: $2,160 or $180.00/mo January 1, 2015: Transition relief for non-calendar year plans in 2015 (100+) 4980H(b) assessment payment: per FT EE receiving subsidized coverage when coverage is unaffordable 2014: $3,000 or $250/mo 2015: $3,120 or $260/mo 2016: $3,240 or $270/mo January 1, 2016: Transition relief for non-calendar year plans in 2016 (50-99) Delayed or Cancelled ndiscrimination Rules for Plans insured ical May not discriminate in favor of highly compensated employees. Employers with self-funded plans are already subject to 105(h) nondiscrimination rules. Waiting for IRS guidance before rules go into effect. IRS has delayed enforcement until plan years beginning sometime after guidance is issued. Automatic Enrollment ical Applies only to employers with at least 200 employees. Repealed by Bipartisan Budget Act of 2015 (vember 2015) Repealed before rules were released.

6 6 Delayed or Cancelled Deductible Limits for Small Group Plans ical Small Originally effective in 2010 As of April 1, 2014, deductible limits were retroactively removed. Retroactively repealed Health Plan ID Number (HPID) Self HIPAA HPID included in certain health plan electronic transactions under HIPAA Indefinitely delayed Originally v 15, 2014 HIPAA Certification Self HIPAA Controlling health plans must certify compliance with HIPAA s electronic transaction standards May need HPID to complete certification Employer doesn t handle HIPAA transactions, will need to get certification from TPA Applies to all HIPAA standard transactions Originally Dec 31, 2015 Small Group Definition insured ical Small employer definition for purposes of underwriting changes to are still subject to the pay or play mandate. Originally January 1, 2016 Cancelled October 2015 States may keep the definition. This summary is provided as an overview of some of the provisions of the Patient Protection and Affordable Care Act (PPACA). For more details or questions, please contact your Parker, Smith & Feek Benefits Team.