Get Ready for Upcoming Affordable Care Act Compliance Deadlines

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    21-Jun-2015
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Just around the corner is an immediate deadline imposed by the Affordable Care Act (ACA), November 5, 2014. Fortunately that is not a difficult one to fulfill. The requirement is to get a "health plan identifier number," or HPID. Small plans -- those through which less than $5 million flows in a year, have a November 5, 2015 deadline. The requirement pertains to the government's desire to simplify HIPAA compliance monitoring. For that, you will need to consult with an accounting professional for details.

Transcript of Get Ready for Upcoming Affordable Care Act Compliance Deadlines

  • 1. Toll Free: 877.880.4477Phone: 281.880.6525Get Ready for Upcoming AffordableCare Act Compliance Deadlineswww.hrp.net

2. Just around the corner is an immediate deadline imposed by the AffordableCare Act (ACA), November 5, 2014. Fortunately that is not a difficult one tofulfill. The requirement is to get a "health plan identifier number," or HPID.Small plans -- those through which less than $5 million flows in a year, have aNovember 5, 2015 deadline. The requirement pertains to the government'sdesire to simplify HIPAA compliance monitoring. For that, you will need toconsult with an accounting professional for details.www.hrp.net 3. Ten days later, November 15, 2014, is the deadline for self-insured employersto submit an enrollment count to the Department of Health and HumanServices in order to establish your 2014 Transitional Reinsurance Fee. The feefor this year is $63 per covered employee. Payment of the fee is due January15, 2015. Note: If your health plan is fully insured, your carrier will take careof this. Data can be submitted via www.pay.govSelf-insured employers have until July 31 next year to pay a similar, but muchless expensive fee, which is the Patient-Centered Outcomes ResearchInstitute Trust Fund fee. The new per-capita fee is $2.08, and is based onaverage plan enrollment over the course of the plan year. That rate applies toplan years ending after September 30, 2014 and before October 1, 2015.www.hrp.net 4. Pay-or-Play Bite BeginsAs is widely known, next year is when most "non-grandfathered" employerswith at least 100 full-time equivalent (FTE) employees will be subject topenalties if they have not complied with the employer mandate. In theory,they were subject to the mandate this year, but will not pay a penalty forignoring it. If your company is in the 50-99 FTE bracket, you have a reprieveuntil 2016.www.hrp.net 5. A quick ACA refresher on this topic: For 2015, you're required to offercoverage to 70 percent of your employees and their dependents, or pay thepenalty. That jumps to 95 percent in 2016 and thereafter.Alternatively, you'll be subject to a penalty if your plan does provide"minimum essential coverage," but that coverage is unaffordable. This isbased on the employee's share of the cost in relationship to householdincome, or based on paying less than 60 percent of the plan's value.Note: If your plan year doesn't coincide with the calendar year, you might notbe subject to the mandate until the first day of your 2015 plan year.www.hrp.net 6. New Out-of-Pocket MaximumsAnother limit on the financial burden employees can be asked to bear hasbeen adjusted upward -- by about 1.6 percent -- for 2015. Specifically, themaximum out-of-pocket limits, combining employee deductibles, co-pays andcoinsurance, cannot exceed $6,600 for employee-only and $13,200 for familycoverage. Ceilings on deductibles for high-deductible health plans offered inconjunction with a health savings account rose to $6,450 and $12,900,respectively. If you have a separate pharmacy benefit plan, employeemaximum costs under that plan must be added to the basic health plan incalculating maximum employee cost-sharing.www.hrp.net 7. Data RoundupMost self-insured health plan sponsors will need to start collecting certainhealth plan data in 2015 to report to the IRS in 2016. These requirements aregoverned by two Internal Revenue Code sections: 6055, pertaining tominimum essential coverage, and 6056, which addresses "large planreporting" (large being at least 50 FTEs; self-insured employers of any size arerequired to supply minimum essential coverage). IRS regulations have beenissued describing these requirements in detail. Draft copies of the reportingforms also are being circulated.The IRS forms require Taxpayer Identification Numbers (TINs, which aretypically Social Security numbers) not only for employees but also for coveredspouses and dependents. The sooner you start chasing down those numbers,the better. The IRS will give employers a one-year pass if they can't gather allthe TINs for the minimum essential coverage form, so long as they havemade a "good faith effort" to get them.www.hrp.net 8. One More ThingRemember the 2013 Windsor v. United States decision requiring ERISA plansto accord the same spousal benefits to same-sex spouses as opposite-sexcouples? Although the ruling wasn't specific on the point, it is consideredadvisable to have a plan amendment reflecting that ruling -- if anything elsein your plan documents would suggest otherwise -- by the end of 2014.www.hrp.net 9. 14550 Torrey Chase Blvd., Ste. 360 Houston, TX 77014 USAToll FreePhoneFax:::877.880.4477281.880.6525281.866.9426E-mail : info@hrp.netwww.hrp.net 10. 14550 Torrey Chase Blvd., Ste. 360 Houston, TX 77014 USAToll FreePhoneFax:::877.880.4477281.880.6525281.866.9426E-mail : info@hrp.netwww.hrp.net