REMINDER: Notice to Employees of Health Insurance Marketplace Due By October 1 st

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1 September 27, 2013 (Updated) REMINDER: Notice to Employees of Health Insurance Marketplace Due By October 1 st Employers are reminded that pursuant to the Affordable Care Act, a notice regarding the Health Insurance Marketplace (or exchange ) under the Affordable Care Act must be provided to all current employees by October 1, 2013, and to all new employees who are hired on or after October 1, This FAQ addresses the notice requirements. Employers can also refer to the technical release published by the federal Department of Labor at: Q: Which employers must provide the notice? A: All employers considered a covered enterprise under the federal Fair Labor Standards Act ( FLSA ) must provide the notice to their employees. To meet the FLSA enterprise coverage test, an employer must have an annual dollar volume of business of $500,000 or more (annual dollar volume generally includes gross receipts and gross revenue, including revenue from sales, commissions, rents, royalties, investment income, and other sources). If separate establishments are under common control or are otherwise closely related, they may be considered a single enterprise for purposes of the dollar volume test. In addition, schools and pre-schools, hospitals, entities providing medical or nursing care, and federal and state agencies are considered covered enterprises under the FLSA. Q: Must I provide the notice to all employees, or only to specific employees? A: The notice of the health insurance marketplace must be provided to all current employees whether they are part-time, full-time, casual, seasonal, etc. The notice must be provided to all employees regardless of whether they are enrolled in any of your group health insurance plans. However, employers are not required to provide any notice to covered dependents of employees, regardless of whether the dependent is enrolled in an employer s group health plan. In addition, no notices need be provided to retirees in a retiree health plan.

2 Health Insurance Marketplace Due By October 1 st Page 2 Q: When must the notice be given to employees and new hires? A: All current employees must be given the notice no later than October 1, In addition, newly hired employees hired on or after October 1, 2013 must be provided with the notice within 14 days of their start date. Note that an employee hired up until Monday, Sept. 30 th would be considered a current employee and should be provided with the notice by October 1 st. Q: What must the notice state? A: The notice of health marketplaces must, at minimum, contain the following information: 1. Information on the existence of the Marketplace (previously referred to as the Exchange) including a description of the services provided by the Marketplace, and the manner in which the employee may contact the Marketplace (the Model Notice refers employees to HealthCare.gov). HEC s model notice form refers employees to the Hawaii Health Connector. 2. A statement that if the employer plan s share of the total allowed costs of benefits provided under the plan is less than 60 percent of such costs, the employee may be eligible for a premium tax credit under section 36B of the Internal Revenue Code (the Code) if the employee purchases a qualified health plan through the Marketplace. 3. A statement that if the employee purchases a qualified health plan through the Marketplace, the employee may lose the employer contribution (if any) to any health benefits plan offered by the employer, and that all or a portion of such contribution may be excludable from income for Federal income tax purposes. The federal Department of Labor has provided two model notices: one for employers who do not provide health insurance to employees, and one for employers who provide health coverage. Obviously, Hawaii employers (except for sole proprietors with no employees) should use the form applying to employers providing health coverage to employees. The federal Department of Labor model notice for employers providing coverage is posted at: Q: Must I use the Model Notice provided by the federal Department of Labor? A: No, employers are not required to use the DOL model notice. However, you must provide a notice which contains the 3 items of information described above. The model notice for employers who provide health insurance specifically states that Page 3 of the model notice is optional. Page 3 invites employers to add optional information regarding the following:

3 Health Insurance Marketplace Due By October 1 st Page 3 Item 13: whether the employee is currently eligible for employer-sponsored health coverage, and if not currently eligible because of a waiting/probationary period, the date the employee is anticipated to become eligible if within the next 3 months; Item 14: whether the employer has a plan that offers minimum value (i.e., whether plan coverage pays for at least 60 percent of the total allowed costs of benefits); Item 15: the premium cost to the employee of self-only coverage under the employer s lowest cost plan that provides minimum value ; Item 16: if the employer anticipates that its health plan will change soon, information on the changes anticipated for the next plan year. Because employers are not required to provide any of the above information, employers who want to avoid unnecessary customization of forms and potential errors should simply omit Items and the entire page 3 of the Model form. In fact, based on a strict reading of the statute, only Part A of the Model Notice form (the first page of the form) and the paragraph on Part B page 2 preceded by a double asterisk is absolutely required. In other words, if an employer wants to meet the bare minimum requirements of its notice obligation, it should provide only the information in Part A (the first page of the Model Notice form), as well as the following paragraph from Part B: ** Even if your employer intends your coverage to be affordable, you may still be eligible for a premium discount through the Connector. The Connector will use your household income, along with other factors, to determine whether you may be eligible for a premium discount. If, for example, your wages vary from week to week (perhaps you are an hourly employee or you work on a commission basis), if you are newly employed mid-year, or if you have other income losses, you may still qualify for a premium discount. The other information in Part B of the Model Notice form is optional, including (a) the employer EIN and employer contact information; (b) the disclosure as to whether the employer provides coverage to all or only some employees; (c) the disclosure as to whether dependent coverage is provided; (d) the disclosure as to whether the employer s plan meets minimum value and is intended to be affordable, and (e) all of Page 3 of the Model Notice form. The aforementioned items are optional because they are not among the 3 items of information which the Affordable Care Act at Section 1512 (Section 18B of the FLSA) requires as part of the notice. HEC has provided its own sample notice in the attached Word document which omits Page 3 of the Model form and includes information about the Hawaii Health Connector. HEC s sample form includes the optional employer identification information, because that information may be useful to part-time employees who are trying to obtain coverage through the Hawaii Health Connector.

4 Health Insurance Marketplace Due By October 1 st Page 4 Q: How must the notices be delivered to employees? A: The notices may be provided to employees by hand-delivery, first-class mail, or electronically, if the employer satisfies the DOL s safe-harbor requirement for electronic delivery at 29 CFR b-1(c). (Although the DOL guidance only states that the notice may be provided by first-class mail or by electronic delivery, hand-delivery to employees should satisfy the notice requirement.) It is not sufficient to merely post the notice on a lunchroom bulletin board or on an employer intranet website. Notices should be delivered separately to each current employee, either by hand-deliver, first class mail, or electronic delivery. Under the DOL s electronic delivery safe-harbor, certain required notices to employees may be delivered electronically if the following requirements are met: Measures to ensure delivery: the employer must take measures reasonably calculated to ensure that the electronic transmission results in actual receipt by the intended recipient, such as using return receipt or notice of undelivered electronic mail features, or periodic reviews or surveys of recipients to confirm receipt. Confidentiality: if private or confidential information is transmitted, reasonable measures must be taken to ensure that electronic delivery protects the confidentiality of transmitted material. Notice of Subject Matter: when documents are furnished in electronic form, notice should be given (either electronically or non-electronically) that apprises the individual of the significance of the document when it is not otherwise reasonably evident as transmitted (i.e. the heading for an communication could read Notice Regarding the New Health Insurance Marketplace ) Employee Access: the employee must have the ability to access electronic documents at a location where the employee regularly performs job duties, and access to the employer s electronic information system must be an integral part of the employee s job duties, or the employee must affirmatively consent (in writing or electronically) to receiving documents through electronic media. See generally 29 CFR b-1(c). Q. What is the penalty for not providing the required notices by October 1, 2013? A. On September 13, 2013, the Department of Labor published an FAQ on its website to answer this question: Q: Can an employer be fined for failing to provide employees with notice about the Affordable Care Act's new Health Insurance Marketplace? A: No. If your company is covered by the Fair Labor Standards Act, it should provide a written notice to its employees about the Health Insurance

5 Health Insurance Marketplace Due By October 1 st Page 5 Marketplace by October 1, 2013, but there is no fine or penalty under the law for failing to provide the notice. See Some attorneys have opined that although the DOL has made this public statement of no fine or penalty, it would nevertheless be prudent to provide the notices because FLSA regulations could be amended in the future to provide for a penalty. In addition, some commentators believe that employers who are plan sponsors have a fiduciary obligation to communicate information to beneficiaries. Although there may be no penalties applicable at this time, HEC believes that employers should strive to comply with the notice requirement by October 1, 2013.

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