Patient Protection and Affordable Care Act (PPACA) Implementation Timeline 2013-2018

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Cross Blue Shield of Michigan will continue to monitor regulations and updates will be provided as soon as they become available. Who qualifies for child-only policies? Individuals who have not attained the age of 21 at the beginning of the plan year are eligible for child-only plans. However, according to the definition of "qualifying child," for purpose of determining tax dependency, a taxpayer cannot include children age 19 through 20 in determination of the taxpayer's premium tax credit eligibility, unless the 19- or 20-year-old fits the criteria for tax dependent status (example, the child is a student). What about tax credits? Premium tax credits are available to taxpayers who purchase coverage on behalf of a qualifying dependent child. A dependent child is defined in the IRS code as: • A child of the taxpayer or descendent of such child or the brother, sister, stepbrother, or stepsister of the taxpayer or a descendent of any such relative; and • Has the same principal place of abode as the taxpayer for more than half of the year; and • Has not turned 19 by the end of the calendar year, is a student who has not turned 24 but the end of the calendar year, or is permanently and totally disabled; and • Has not provided over one-half of his or her own support for the calendar year; and • Has not filed a joint return with his or her spouse. The ACA specifies that the parent who claims the child on their tax return is responsible for providing that child with coverage. In some cases, this may not correspond with child or medical support orders.

New Hire Automatic Enrollment – 2014 Employers will not be required to comply with this provision until regulations are issued. Regulations are not expected before 2014. Agent Action At this time, there is no need for employers to develop a plan to automatically enroll employees in coverage Description The Patient Protection and Affordable Care Act (PPACA) requires employers with more than 200 full-time employees, that offer one or more health benefit plan options, to automatically enroll new full-time employees (full-time employees are those who work, on average, 30 or more hours per week) in one of these plans. The employer must give "adequate notice" to employees of their automatic enrollment and the opportunity to opt out of coverage. Employers must also automatically continue existing elections for current full-time employees from year to year. Automatic enrollment is subject to any applicable waiting periods authorized by law. Waiting periods in excess of 90 days will be prohibited under PPACA as of 2014. Pending Legislation: We are awaiting regulations that detail when this will be effective, how it will be implemented and which plan the employee must be automatically enrolled in when an employer offers multiple plan options.

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