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January 6, 2015


What’s ahead for you in 2015 to be (or remain) compliant with the Affordable Care Act?  The answer depends on a number of factors including whether your company is an applicable large employer and the number of employees you have.

Does the following sound like a recipe for a headache?  Changing your benefits strategy, having to collect a myriad of data not previously collected and integrating this among several roles within your organization to meet IRS reporting guidelines.  Whatever your company size, Western Growers and Western Growers Insurance Services are ready to help.


100 or more EMPLOYEES

For the largest of the employers (those with 100 or more employees), much analysis and effort was most likely spent in 2014 to bring the company into compliance by putting into place a benefit strategy and plan that would meet legal guidelines.  The timeline for reporting seems a bit distant — the first reports to employees are not due until January 31, 2016, and reports to the IRS don’t seem to be on the calendar until February 29, 2016 (March 31, 2016 if filing electronically).

But don’t be lulled by this timeline.  To be able to do the reporting required in 2016, you need to have started data collection by January 1, 2015.  While the reporting occurs annually, compliance (and related taxes/penalties) will be assessed on a monthly basis.



For groups in the 50-99 employees category, the upcoming year will be a review of benefit strategy and compliance.  True, the limited Internal Revenue Service reprieve from reporting on their 2015 offer to employees for these groups gives extra time until they are mandated to report.  However, experience from 2014 has demonstrated that getting to a compliant benefit strategy that meets the company’s needs requires more time, analysis and planning than you might have initially expected.  Also, if the company is not already offering a benefit plan that complies with minimum value guidelines and is affordable, 2015 will be a planning year to effect changes by January 1, 2016.



Groups that employ fewer than 50 people don’t get to skip this discussion.  There are two items that will be on the table for you.  First, though the small group employers don’t have a mandate to make an offer of coverage to employees and their dependents, the individual mandate is in play.  You need to consider the mandate as you set your benefit strategy.  Second, the demands of attracting and retaining a skillful labor pool may require continued evaluation of how the company’s position on offering benefits serves as a competitive advantage or disadvantage.

This is what we can see based on what is on the table today… are changes likely to be coming forward? If so, we will continue to assess and address.  Meanwhile, WGIS remains on top of how best to serve our members.  We are here to provide you the business consultation to help you effect solutions that match your strategic direction in addressing all your insurance needs.  For more information, contact me at: [email protected], or 949.885.2391, or go to our website

What’s That Mean?

Applicable Large Employer: Your company’s Applicable Large Employer status is based upon its average number of full-time equivalent employees (employees expected to work 30 or more hours per week) in the prior year.  If you employed 50 or more full-time equivalent employees in the prior year, your company is considered an Applicable Large Employer.

Individual Mandate: This is a piece of the Affordable Care Act that says nearly everyone must have health insurance that meets minimum standards. With some exceptions, people who do not maintain health insurance coverage have to pay a penalty.  In 2015, that penalty for not having coverage increases to $325 per person (or 2% of income) — that’s up from $95 per person (or 1% of income) in 2014.