Here are some tips to help employers develop a compliance strategy and be made aware of upcoming requirements for employee group health plans for the upcoming 2016 year.
Plan Design Changes
- If changes were made to grandfathered plans, they may go beyond permitted guidelines and may no longer be grandfathered.
- Effective January 1, 2014, non-grandfathered plans are subject to limits on cost sharing for essential health benefits. The ACA’s annual limit (out-of-pocket maximum) applies to these plans, as well as self-insured health plans. A health plan’s out-of-pocket maximum for essential health benefits cannot exceed $6,850 for self-only coverage and $13,700 for family coverage.
Health FSA Contributions
- Effective January 1, 2013, employees’ annual pre-tax salary reduction contributions to a health flexible spending account must be limited to $2,500 and will not impact contributions under other employer-provided coverage.
- Reinsurance contributions are only required for health plans that provide major medical coverage.
- Health plans must submit statement with the Department of Health and Human Services certifying their compliance with HIPAA’s electronic transaction standards.
- Confirm whether your health plan is a controlling health plan (CHP) that is required to provide the initial HIPAA certification.
Employer Penalty Rules
- Applicable large employers (ALEs) that don’t offer affordable health coverage to full-time employees that provides the minimum value will be subject to penalties if any employees receive subsidies for health coverage through Exchange.
- Penalty rules apply to ALEs with 50 or more full-time employees.
- There is a special exemption for employers with seasonal workers – if workforce exceeds 50 employees for 120 days or fewer during calendar year, you do not qualify as an ALE for 2016.
For further ways to account for potential penalties, please see our more detailed PDF outlining specific penalty codes and corresponding fines. There is also information as to which tax forms to file depending on the size of your company and the amount of health coverage you provide to your employees.