If you are an employer with 50 or more employees, you should read this. If you are an employer at all, you should read this. Federal health care reform affects us all, so this article series will tell you more about what you need to know.
To start, below are a couple of facts that you may already know:
– Beginning in 2014 the Patient Protection and Affordable Care Act (PPACA) requires that private health insurance plans that are offered should meet minimum essential coverage requirements.
– An insurance exchange will be established to pool risks and ostensibly offer competitive rates—States have the latitude to create their own or rely on the federal insurance exchange.
– There will be four (4) tiers of plans within the state or federal insurance exchange (Bronze, Silver, Gold, and Platinum)—these will meet the Minimum Essential Coverage and Minimum Value requirements of the law.
Now, having identified some of the requirements of the Patient Protection and Affordable Care Act (PPACA), let us tell you what has been delayed, what is still in play, and allow you to take a bit of a deep breath:
What Has Been Delayed
The Pay Or Play provision requiring large employers (50 or more full time equivalent employees) to:
-Offer minimum essential coverage to 95% of full time employees
-Offer minimum value coverage to full time employees
-Offer affordable coverage to full time employees (less than 9.5 percent of income)
-Consider employees averaging 30 or more hours per week full time eligible employees and offer them access to the health plan
-Count and tally employees’ hours to determine if they average 30 or more hours per week
What is Still Required
-Medical Plan waiting periods cannot be more than 90 days from the employee eligibility date
-All pre-existing condition limitations must be removed
-Out of Pocket maximums cannot exceed $6,350 for individual and $12,700 for family coverage
-Children may continue to be covered under their parents’ plan to age 26
-Wellness program requirements
-Small insured plans must include essential health benefits, at bronze, silver, gold or platinum levels with a deductible not to exceed $2,000 for Individuals and $4,000 for family coverage.
-Providing Summary of Benefits and Coverage during Open Enrollment (See Section Below)
-Distributing the DOL notice regarding the availability of exchanges by October 1, 2013. (See Section Below)
-Transitional Reinsurance Fees will still be assessed in all small and large employer medical plans.
Summary of Private Health Insurance Benefits
With the 2014 date fast approaching, there are a few things that your company may need to do. First, please note that large group eligible employers MUST give a Summary of Health Insurance Benefits and Coverage to every employee starting in 2014. This was a requirement for any plans with open enrollment periods starting 10/1/2012. These summaries will be used by employees who shop the federal insurance exchange, compare coverage from spouse employer, etc.
Federal Insurance Exchange Notices
Employers of all sizes will have to provide state or federal insurance exchange notices by 10/1/2013 that will notify the employee of the availability of the federal insurance exchange, if the employer offers coverage, if they are eligible for coverage, and if the coverage meets minimum value and is deemed to be affordable. Remember that if you meet the “affordability” and “minimum value coverage” as a large employer, you are still in safe harbor. But you are going to have to notify your employees that you meet these criteria so that the employee will be armed with this information when they start to price exchange coverage, tax subsidy eligibility, etc.
Our next federal health care article will talk about what qualifies as a large group eligible employer, and how you can stay in safe harbor. Have any questions? Let us know! As a professional employer, it is our joy to make your business life easier and less complicated.