Few topics have garnered as much recent attention in the HR field as the Affordable Care Act (ACA). Now that we’re halfway into 2015, here are some high-priority compliance issues to be aware of for the remainder of this year.
1. Measurement Period for Number of Employees
Employers should have established a Measurement or Stability Period by January 2015 for variable hourly/seasonal employees. If you have not done this yet, you need to do so immediately. Please call us for guidance about establishing a Measurement Period.
Although it is unlikely, you may qualify for one of the eight forms of relief. For more information, see section XV.D.1 through 7 of the preamble to the ESRP regulations.
2. Section 125 Modifications
Employees can make 2015 mid-year election changes, if they
- intend to enroll in a Qualified Health Plan on the Exchange.
- work less than 30 hours per week during the Measurement Period.
If you have not modified your Section 125 Plan documents to reflect this, now is a good time to do so.
3. Premium Reimbursement Grace Period for Small Employers
Until July 2015, employers with less than 50 full-time (FT) and/or full-time equivalent (FTE) employees can continue using a premium reimbursement plan for their employees’ individual policies without penalty.
4. 1094-C and 1095-C Reporting
Applicable Large Employers (ALE) must collect data this year on major medical coverage offerings so they can be prepared to report to the federal government in 2016 on Forms 1094-C and 1095-C.
5. Employer Mandate Reprieve
ALEs with 50 to 99 FT/FTE employees will not be subject to the Employer Mandate for the 2015 calendar year, as long as they did not
- significantly reduce benefit eligibility.
- reduce the benefits previously offered to employees and dependents since February 2014.
6. Small Group Extension for Non-Compliant Plans
Small group and individual health plans that are not grandfathered/grandmothered, and not ACA-compliant, may continue to be offered until 2016.
7. Plan for the Cadillac Tax
Health benefits (including HRAs, HSAs, FSAs) valued above the IRS threshold ($10,200 for individual and $27,500 for family) will be hit with a 40% excise tax, known as the "Cadillac Tax," starting in 2018. Many employers are already considering strategies to reduce the cost of their high-priced health plans. This tax could have a deep impact on financial projections for the next few years. It may also impact an employer’s ability to attract talent based on their benefits package.
Call Us for Help
Medical insurance continues to be a tough issue, and we don't expect that to change any time soon. We are here to help you navigate the rough spots and remain compliant. If you have any questions or concerns, please give us a call.