PPACA 2016 Checklist

 

Health Care Reform Checklist for 2016

Please contact my office, your insurance carrier or a knowledgeable employment law attorney for more information.  Or, current clients may login to HR360 for a more detailed list.  
 

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1. Evaluate Grandfathered Status of Group Health Plan

A grandfathered plan is one in existence as of March 23, 2010. Grandfathered plans do not have to comply with certain ACA rules.

2. Review Plan Documents for Required Changes to Plan Benefits

Some small businesses can continue to renew group policies up to January 1, 2018, that do not comply with all ACA requirements, if that benefits the employer from a cost perspective.

3. Analyze Tax-Favored Arrangements 

Employers who maintain cafeteria plans, HRAs, and health FSAs should confirm that these arrangements comply with several ACA changes that took effect in 2014. 

4. Provide Required Notices to Employees and Dependents

Availability of Health Insurance Exchanges (Notice of Coverage Options)

Summary of Benefits & Coverage (SBC)* and Notice of Plan Changes

NOTE: As a client of EB Solutions, both notices are provided/displayed on your personalized employee benefit plan(s) website.

5. Determine "Pay or Play" Responsibilities

Beginning in 2015, certain large employers will be subject to the ACA employer shared responsibility (ESR) provisions.  Otherwise know as "pay or play."  

Employers with 100 or more full-time employees (including FTEs) and employers with 50 to 99 full-time employees (including FTEs) that do not qualify for the transition relief are subject to "pay or play" in 2015.

Large employers with 50 to 99 full-time employees (including FTEs) that certify they meet certain eligibility criteria  will not have to comply with "pay or play" until 2016.

6. Prepare for Compliance With Information Reporting Requirements (Forms 1094 & 1095)

Information reporting is now required for companies with 50 or more full-time employees, thanks to "pay or play" provisions. 

7. Other Action Item for 2016

Medical Loss Ratio (MLR) Rebates. 

Employers must distribute rebates received from insurance companies to enrolled, eligible employees. Insurance carriers are required to send rebates checks to employers by September 30th. These rules do not apply to employers who operate self-insured plans.

 

Please visit  www.HealthCare.gov for the latest information.