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Mercer

Recent triagency guidance finalized the template and related materials for the ACA’s summary of benefits and coverage (SBC). The new SBC materials will apply for the first annual open-enrollment period starting on or after April 1, 2017, for a plan year beginning on or after that date. This means calendar-year group health plans will use the new SBC materials during fall 2017 open enrollment for the 2018 plan year. Plans that don't hold annual open enrollment will have to use the revised SBC materials starting with the first plan year that begins on or after April 1, 2017. The new template is available on CMS website.

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Happy to be a part of this! This is a great New York Times article that backs up what we’ve been saying all along.

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While the IRS has not yet published official 2017 dollar amounts for ACA “play or pay” assessments, Mercer has projected them, using the medical premium inflation factor in the HHS regulations. The following table shows the annual amounts, though employers incur assessments on a monthly basis.

ACA pay-or-play assessments (Section 4980H) Projected 2017 2016 2015
Not offering coverage (4980H(a)) $2,260 $2,160 $2,080
Offering coverage lacking minimum value or affordability (4980H(b)) 3,390 3,240 3,120

 

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Public opinion on the ACA has been deeply divided since day one, and it remains so today. Kaiser has been tracking the public’s views on the law since 2011 and recently created a cool interactive graphic that cuts polling results by various demographics and shows how opinions have changed (or not) over time. Of all the demographic slices here, it appears that political party identification is most indicative of one’s views on the ACA. Take some time to play around with the tracking poll here.

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This week, all eyes are on the presidential hopefuls as the primary election season kicks into high gear. With health care on the docket as one of the key domestic policy issues of this election, it’s important for voters to know where each candidate stands, relative to the ACA and Medicare.

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The average age of first-time mothers in the U.S. is now at an all-time high of 26 years old, according to a recent release by the CDC. Still, many first-time mothers are under 26 – which means, thanks to the Affordable Care Act, they are eligible as dependents on their parents’ health insurance plans. But getting coverage for labor and delivery as an adult child on a parent’s plan can be tricky. As Mercer employee benefits attorney Wade Symons explains, “the ACA requires well-woman services to be provided, including prenatal care, but not labor and delivery or other maternity costs.” In addition, having the newborn baby covered under the mother’s parents’ plan “would be covering the dependent of a dependent…Employers won’t offer health insurance for their employees’ grandkids." This creates a situation where the mother-to-be will need to seek other options for coverage to make sure she and her baby are covered appropriately. One option is the public health insurance exchange, though Symons clarifies that  “there are only limited periods of open enrollment” and that some women “may not qualify for a special enrollment if [they’re] pregnant and voluntarily opt out” of their parent’s coverage.  If you don’t cover maternity services for adult children, you might want to review health plan materials to make sure this is clear and help avoid unpleasant surprises.

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Earlier this month, employers let out a sigh of relief when the delay of the Cadillac tax was announced. And they’ve just been given some more breathing room with the extension of deadlines to provide and file required IRS information returns and employee statements. Employers now have until March 31, 2016 to distribute 1095 forms and provide minimum essential coverage (MEC) and employer shared-responsibility (ESR) statements to individuals (the previous deadline was February 1). In addition, the deadline for transmittal of the 1094 forms to the IRS has been extended from March 31 to June 30, 2016 for electronic filings, and from February 29 to May 31, 2016 for non-electronic (paper) filings.

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It’s a done deal! Federal spending legislation cleared by Congress today for the President’s expected signature contains a two-year delay of the excise tax on high-cost plans. Assuming the tax does go into effect in 2020, the cost threshold will be the same indexed amounts they would have been without the delay. However, the U.S. Comptroller General will conduct a study on appropriate age and gender adjustments in consultation with NAIC.

 

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As you finalize medical plan designs for 2016, make sure you consider these five compliance elements of the Affordable Care Act (ACA).

 

1. Embed individual out-of-pocket (OOP) limits. The ACA’s annual in-network OOP statutory limit for self-only coverage ($6,850) applies to all individuals, whether enrolled in self-only coverage or another tier (e.g., family). Be sure to confirm your medical carrier’s capabilities to adjudicate this benefit design feature. The penalty for non-compliance is $100 per day per individual.

 

 

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Traditionally, employers have not thought of opt-out credits as increasing the cost of employee coverage. But in a recent HIPAA FAQ unrelated to affordability, regulators said that cash payments — or opt-outs — offered only to employees likely to generate high claims costs violate HIPAA’s prohibition against discrimination on the basis of health status.

 

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The ACA requires most people to have insurance or pay a penalty. That means employees with adult children need to think twice about discontinuing health coverage for their dependent children as they get older. As long as an employee is claiming a child as a dependent for income tax purposes, they need to be sure the child has health insurance. At tax time, filers are required to show everyone in the household had health insurance (See lines 46 and 61 of Form 1040). In 2015, the penalty is the greater of 2% of household income or $325 per person. You might want to remind your employees of this in time for open enrollment.

 

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The ACA reporting deadlines for minimum essential coverage and employer shared responsibility occur in the first quarter of 2016. Individual statements (Form 1095-Cs) have a Monday, February 1, 2016, deadline and the IRS electronic transmittal due date (Form 1094-C) is Thursday, March 31, 2016.

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