You thought you had it figured out and were on course to comply with the mandates under the Patient Protection and Affordable Care Act (PPACA). You thought you could move on — until Election Day.
On Tuesday, November 4, 2014, the Treasury Department issued a new challenge. It acknowledged the supplied calculator designed to gauge whether or not a plan met “minimum value” fell short of the intent of the law. As a result — it’s back to the drawing board.
Sayonara Skinny Plans
You may have seen variations in plan designs that range from the traditional style plans to what have been called “skinny” plans. These plans were created to help curb an employer’s expense while providing some benefit to its workforce. Skinny plans took root for employers looking to keep costs at a minimum while mitigating future potential taxes (fines) associated with not offering a minimum essential coverage (MEC) plan that was affordable and met minimum value. For example, some skinny plan designs did not include coverage for hospitalization.
What does this mean to you? If your company elected a “skinny” plan before November 4, 2014, it can keep using the plan, but only until its next plan renewal. If your company had not yet committed to this plan before November 4, then to meet requirements any plan you offer must now include those benefits (such as hospitalization) that were excluded previously to bring down the cost of the plan.
But wait — there’s more
What about demonstrating that you are compliant with the mandates of PPACA? While the draft forms for reporting were released in August 2014, we all await final regulation.
What you cannot wait for is being prepared for a reporting effort that will involve integrated data and coordination between varied departments within your company (human resources, payroll, benefits and tax preparation).
If your company has 100 or more employees, the date for reporting is rapidly approaching. Starting January 1, 2015, you will need to document the following each month for reporting purposes:
- the plans you have offered
- the cost of the plan
- the cost charged to each employee
- to whom you’ve offered coverage
- who has elected coverage (vs. waived)
- the Social Security number (SSN) for each covered person
Your data collection needs to start January 1, 2015, to be able to report by January 31, 2015. If your company has fewer than 100 employees, get ready…your day is coming.
We can help
For information about what benefit plans might help you with your business needs or the reporting requirements coming up, contact WGIS. We can consult with you on this effort and help you in your efforts to comply with the current and future evolutions that unfold under PPACA.
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