Sunday, October 22, 2017
 

Changes Affecting Employers and Group Health Plans -- 2015 and Beyond

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Becker Suffern McLanahan, Ltd.

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2015

Shared responsibility ("play or pay") requirements (large employers)

  • Employers with 100 or more full-time employees (or full-time employee equivalents) who fail to provide minimum, affordable coverage to full-time employees are subject to penalties

Employer reporting and notice requirements (due in early 2016 based on 2015 activity)

  • Plan sponsor (if self-funded) or insurer reporting if providing minimum essential coverage
  • Employer reporting if 50 or more full-time (or full-time employee equivalents) about furnishing of minimum value and affordable coverage

2016

Shared responsibility ("play or pay") requirements (mid-size employers)

  • Employers with 50 or more full-time employees (or full-time employee equivalents) who fail to provide minimum, affordable coverage to full-time employees and their dependents are subject to penalties.

Small group market size

  • "Small group" is redefined as 1 - 100 employees for purposes of the insurance market for non-grandfathered plans (including SHOP)
    • Essential health benefits required at "metal" levels of coverage - platinum (90%), gold (80%), silver (70%), and bronze (60%)
    • Guaranteed issue and renewability
    • Modified community-rating ("fair health insurance premium") requirements
    • Common insurance risk pools
    • Premium stabilization programs and health insurance provider fee

2017

SHOP coverage

  • States have the option to expand SHOP coverage to employers with more than 100 employees.

2018

Excise tax on high cost ("Cadillac") plans

  • 40% excise tax on benefits that exceed a general threshold of $10,200 for single coverage and $27,500 for coverage of more than one person

Effective Date Not Established

Nondiscrimination requirements

  • Currently applies to self-funded plans
  • Effective date for fully insured plans indefinitely delayed
  • Will likely impact ability to provide different eligibility, benefits, and contributions to different groups

Automatic enrollment

  • Applies to employers with more than 200 employees
  • Effective date delayed indefinitely

 

1/28/2015

 

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