State Based Exchange - How to Qualify For a FTE

Transcription

1 Presented by: Kevin Kuhlman National Federation of Independent Business

2 State Decision Update Small Employer Responsibilities Individual Mandate Individual and Small Business Exchanges Affordable Coverage Employee Firewall Large Employer Responsibilities Question & Answer resources/healthcare

3 Expand Medicaid up to 138% FPL? Maintain current eligibility levels Exchange development? State Based Exchange Federally Facilitated Exchange Federally Facilitated Partnership Exchange Essential Health Benefits selection? Select from limited menu of health plan options Default to largest small group market health plan

4 Employer controlled group and affiliated service group aggregation rules. Employee NOT leased, NOT temporary employees, NOT independent contractors. Full time Employee 30 hours/week (130 hours/month). Full time Equivalent (FTE) Employees total monthly part time hours/120. This includes seasonal employees. Seasonal Worker reasonable, good faith determination for Large business 50 or more full time employees or full time equivalent employees (FTEs) as of Small business fewer than 50 FTEs as of Seasonal worker exception business can remain small if >50 employees for <120 days (or 4 calendar months) due to seasonal workers.

5 Small Non Offering Small Offering Large Non Offering Large Offering EMPLOYER MANDATE PENALTIES AND REPORTING REQUIREMENTS HAVE BEEN DELAYED ONE YEAR UNTIL 2015 SIZE DETERMINATION CALCULATIONS AND FULL TIME STATUS OF EMPLOYEES WILL BE NECESSARY IN 2014

6 Your Business Small business fewer than 50 FTEs NO requirement to offer health insurance to full time employees or pay penalties Your Employees Individual mandate requirements/expectations in 2014 Individual Exchange eligibility and subsidies in 2014 Notice of Coverage Options/Exchange Availability in

7 Minimum essential coverage o Employer sponsored insurance (including grandfathered health plan), o Individual coverage, o Government insurance Medicare, Medicaid OR Penalty Tax o Greater Amount Applicable income Flat amount o Enforcement

8 Qualified Individuals Employees of non offering businesses or employees with unaffordable insurance coverage in 2014 Cost sharing subsidies/tax credits modified adjusted gross household income % FPL Purchased with after tax dollars Qualified health plans New plans will be based on metal levels that correspond to actuarial values Bronze, Silver, Gold, Platinum Must provide minimum value Federal Poverty Level (FPL) Income/Wages Max Premium (% of Income) 100% 133% $11,490 $15,282 2% 150% $17,235 4% 200% $22, % 250% $28, % 300% $34, % 400% $45, % Potential benefits more choices, less administrative costs Costs increased benefit mandates, Individual Exchange premium fee

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10 Premiums and Max Premium % based off Silver plan (70% actuarial value) Premiums paid with after tax dollars

11 Your Business NO requirement to offer health insurance to full time employees or pay penalties Reporting/Verification of employee coverage in 2015 Voluntary disclosure of health insurance costs on employees W 2 forms Temporary small business tax credit Your Insurance All insurance market reforms in 2014 EHB, deductible limits*, annual/lifetime cap elimination, dependent coverage up to age 26, minimum value (60% AV), maximum out ofpocket caps, no cost sharing for preventive services, etc. SHOP Exchange eligible in 2014 Small Business Health Insurance Tax (HIT) in 2014 Nondiscrimination requirements 90 day waiting period limit in 2014 Your employees Affordable health insurance Notice of Coverage Options/Exchange Availability in

12 Small Business Health Options Program marketplace for small businesses to shop for health insurance coverage for employees Employee enrollment all or none Qualified employer 2014 businesses with up to 50 employees 2016 SHOP must open up to businesses with up to 100 employees 2017 SHOP may open up to all size businesses Small business health insurance tax credit Full credit eligibility <10 employees; average wages <$25,000/year Credit phases out 25 employees; average wages <$50,000/year Employer must contribute at least 50% toward employees premiums calculator Potential benefits lower administrative costs; more coverage options; more contributions arrangements Costs SHOP Exchange premium fee; increased benefit mandates

13 Applies to offering employers (large and small) Employee s taxable wages Box 1 of W 2 statement Lowest cost self only health insurance premium option Employee s contribution to that premium Affordable coverage Employee s contribution to lowest cost, self only health insurance premium <9.5% employee s taxable wages Employee Firewall Employee PROHIBITED from cost sharing subsidies/tax credits if coverage is affordable Employees with unaffordable insurance PERMITTED access to costsharing subsidies/tax credits in individual exchange Affordability definition does not apply to dependent or family coverage Spouse/Dependent Firewall Dependents and families WILL NOT have access to cost sharing subsidies/tax credits in individual exchange

14 Coverage Self Only Federal Poverty Level (FPL) Income/ Wages Firewall Annual Premium Employee Contribution Employer Contribution Employer Contribution % 100% $11, % $7,800 $1,092 $6,708 86% 200% $22, % $7,800 $2,183 $5,617 72% 350% $40, % $7,800 $3,820 $3,980 51% 401% $46, % $7,800 $4,377 $3,423 44% Employer sponsored insurance remains tax preferred

15 Your Business Employer mandate determinations in 2014 Reporting/Verification of employee health coverage in 2015 Voluntary disclosure of health insurance costs on employees W 2 forms (Mandatory for businesses with >250 W 2s) Your Insurance Fewer requirements than small employers in 2014 Minimum value (60% AV), no annual/lifetime caps on benefits, no cost sharing for preventive services Nondiscrimination requirements (delayed) 90 day waiting period limit in 2014 Auto enrollment (>200 employees) will not be required in 2014 Your Employees Look back measurement period to determine full time status (3 12 mo.) in 2014 Administrative period (1 3 mo.) Stability period for offer/non offer (6 12 mo.) in 2015 Affordable health insurance $3,000 penalty per unaffordable employee in 2014 Notice of Coverage Options/Exchange Availability in

16 Your Business Employer mandate penalties in 2015 Penalty liability = (Total number of full time employees 30) x $2,000 Penalties are non tax deductible Your Employees Individual mandate expectations in 2014 Individual exchange eligible in 2014 Notice of Coverage Options/Exchange Availability in

17 Kevin Kuhlman (202) Resources: NFIB Small Business Healthcare Playbook healthcare lawguide nfib.pdf NFIB Healthcare Reform Resource Center