Mid-Sized Group (50 to 99 Employees) Insured Plans and PPACA
PPACA brings numerous responsibilities and options to employers. Below is a summary of the PPACA provisions that apply to group health plans and whether the provision applies to insured mid-sized group plans.
Provisions Effective 2014 or Later
Provisions Effective 2010 - 2013
* Does not apply in whole or part to grandfathered plans.
+ To qualify, the employer may not reduce the size of its workforce or the overall hours of service of its employees so that it falls below 100 full-time and full-time equivalent employees unless there is a change in its business. It also may not materially reduce its contribution level, reduce plan benefits so that they fall below minimum value, or reduce the classes of employees or dependents eligible for coverage from what was in place on February 9, 2014
# States have the option to renew policies that do not meet all of the PPACA requirements through Oct. 1, 2016. If renewal of “non-compliant” policies is allowed, this requirement will not apply to the renewed policies.
Note: For 2014 and 2015 a group is considered small for the insurance market requirements of PPACA if the group has 50 or fewer employees. Beginning in 2016, a group will be considered “small” for the insurance market requirements if the group has 100 or fewer employees. (In most states part-time employees count pro rata toward full-time equivalent employees using the same method as the employer shared responsibility/play or pay requirement.)
In contrast, for purposes of the employer shared responsibility/play or pay requirement, for 2015 an employer generally will not be considered “large” unless it has 100 or more full-time or full-time equivalent employees. Beginning in 2016, an employer will not be considered “large” for purposes of the employer shared responsibility/play or pay requirement unless it has 50 or more full-time or full-time equivalent employees.