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Compliance Items to Address in 2015 JUST IN TIME FOR THE NEW YEAR. By Forum
2. PREMIUM REIMBURSEMENT PLAN. IRS and DOL state that health insurance reimbursements (HRA) not integrated with a group health plan or employer payment plan are themselves a group health plan and therefore violate the ACA. Employers are no longer permitted to reimburse employees or pay insurers directly for individual policies. 3. MARKETPLACE / MEDICARE DUMPING. It is not acceptable to identify high cost claimants and provide a cash incentive for employees to drop employer coverage and then obtain
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< EMPLOYER REPORTING 2015 REQUIREMENTS. Section 6055 - Minimum Essential Coverage Notice. This notice informs the employee and their dependents if their plan meets minimum essential coverage and when they were eligible for the plan. Fully insured carriers will file this on behalf of the employer. If you are self-insured, your health broker will help you in providing the notice. Section 6056 - Creditable Coverage Notice. All employers with 50 or more full time equivalent employees must file. This covers minimum value and contribution. individual coverage on the Marketplace or through Medicare. The agencies say this practice discriminates for two reasons. (1) Individuals with adverse health factor must forgo the cash to elect group health coverage causing them to pay higher premium than healthier employees. (2) HIPPA nondiscrimination rules allow “benign discrimination” (discrimination that helps individuals with adverse health factors). This practice discourages enrollment in group health plan and is therefore, not benign.
4. SAME-SEX MARRIAGE. The IRS and DOL have indicated that they will consider the term “spouse” to include individuals married to a person of the same sex who were legally married in a state or foreign jurisdiction that recognizes such marriages, regardless of what state they reside in. In the states that recognize same-sex marriage, a fully insured health plan under their state law, says employers that provide benefits to spouses must also offer coverage to samesex spouse.
5. TRANSITIONAL REINSURANCE FEE. The PPACA created the Transitional Reinsurance Program with the goal of stabilizing the effect of high risk individuals entering the individual market. This program is a temporary 3 year program (2014, 2015, 2016) and will be paid by health insurers and self-funded health plans. These fees will be passed on to the employers and insured individuals. The fee for 2014 is $63.00 per covered life, per year. HHS estimate for 2015 will be $44 per covered life, per year.
Forum is a team of employee benefit experts whose sole purpose is to make health benefits easier for shareholders, HR administrators and employees. Better than anyone, we know how to navigate the complex and ever changing landscape of health, life and disability insurance so our clients can focus on running their business and doing what they enjoy. Visit forum at www.forumbenefits.com for more information.
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