Earlier this month, we learned that the pay-or-play employer mandate portion of the Affordable Care Act would be postponed a year, so its requirements wouldn’t kick in until 2015.
Woo hoo! Time to kick back with a cold beverage and think about something other than health care legislation, right?
Well… we hate to tell you, but you’re not completely off the hook for ACA stuff between now and January 1, 2015. There are still some obligations for employers:
This year:
- Distributing health care exchange notices. You must notify all your current employees that they have the option to purchase health insurance through an exchange by October 1 of this year. After that, this info must be given to new hires in their paperwork.
- Paying your comparative effectiveness fee. If your health plan year ends before October 1, you have to pay a fee of $1 per year per person covered by the plan (averaged over the previous year). Next year, the fee will go up to $2 per person. Oh, and the first-year’s payment is due on Wednesday (July 31).
If your health plan year ends on or after October 1, your fees won’t kick in until next year. They’ll still go up to $2 the following year; fees for all plan dates will be adjusted for inflation until the fee expires at the end of September 2019. What is the fee supposed to cover? A government institute that “advances the quality and relevance of evidence-based medicine.” - You’ll also want to make sure the health plan you’ll offer in 2014 meets these conditions:
- Employee coverage begins in 90 days or less
- Coverage cannot be denied to employees because of preexisting conditions
- There are no annual or lifetime dollar limits on essential health care
Next year:
- Paying your reinsurance program fees. Next year, employers will have an additional fee of $63 per employee (averaged over the previous year). The fee per employee is expected to drop to about $42 per employee in 2015 and about $26 per employee in 2016. This fee reimburses insurance companies that wind up covering lots of people with preexisting conditions.
- Making sure your SBCs are updated. The summary of benefits and coverage (SBC) documents that accompany group health plans will have to state whether or not the plan provides minimum essential coverage and whether that coverage meets the minimum value standard.
So there’s still plenty of work to do in preparation for the Affordable Care Act. That cold beverage might have to wait…