Employers can use this clear and concise guide to understand what action steps they need to take (and when) in order to comply with the various requirements of the Affordable Care Act. This includes Plan Design Requirements for both grandfathered and non-grandfathered plans; Notice Requirements; and Reporting Requirements for plan sponsors and employers.
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Employer Health Care Reform Action Items for 2014-2015
1. Employer Health Reform Action Items For
2014/2015
Plan Design Plan Design
Requirements
All Health Plans Non-Grandfathered Plans
Requirements
Ban on preexisting condition exclusions
imposed on anyone
Full implementation of ban on annual
limits and the dollar value of essential
health benefits (EHB)
Guaranteed renewability of coverage
2014 Plan Years
beginning on or after:
JAN 1
JAN 1
JAN 1
JAN 1
JAN 1
JAN 1
Guaranteed availability of coverage
Fair health insurance premiums for small
group and individual markets – adjusted
community rating (ACR) applies
Full implementation of extension of
dependent coverage until age 26
2014 Plan Years
beginning on or after:
Ban on determination against health
care providers ("any willing provider" type
laws)
JAN 1
JAN 1
JAN 1
JAN 1
Coverage for individuals participating in
approved clinical trials
Increased limit in outcome-based
incentives/disincentives permitted in
wellness programs from 20 to 30%; or up
to 50% for tobacco-free programs
Ban on waiting periods exceeding 90
days
Cost-sharing limitations for out-of-pocket:
applicable to insured plans offered via
the Marketplace, and insured and self
funded plans offered outside
Marketplace; $6,350 for single coverage,
$12,700 for coverage for more than oneJAN 1
2. Employer Health Reform Action Items For
2014/2015
Notice Notice
Requirements
What Employers Must
Provide and When
What Employers Must
Provide and When
Requirements
Due By:Due By:
Include in all plan communications:
Maintenance of Grandfathered Health
Plan Status, if applicable, until plan loses
GF status
Patient Protections Notice: Right to
Designate a Primary Care Provider (PCP)
and Right to Direct Access to OB/GYN to
all affected participants
Ongoing
Upon
Coverage
Upon
Application
Summary of Benefits and Coverage
(SBC): from plan sponsor to participants
upon application, by the first date of
coverage, within 90 days of enrollment
by special enrollees, upon contract
renewal, upon request
Model Wellness Program Disclosure: Notice
of Reasonable Alternative Standards for
outcome-based health contingent wellness
program; to all eligible participants upon
enrollment
Upon
Coverage
30 Days
Prior
Advanced Notice of Rescission
(cancellation) of Coverage: Advance
notification by Plan to affected
individuals of rescission of coverage
New
Hires
Provide Notice of Marketplace Options to
all new hires within 14 days of hire
Advanced 60-day notice of change in
benefits from Plan Sponsor to Participants
not reflected in most recently provided
SBC (other than with renewal or re-
issuance of coverage)
60 Days
Prior
Beginning 2016, provide Benefit
Statements to employees based on
employer reports to IRS via Form 6055
and 6056 Reports on 2015 year
JAN 31
3. Employer Health Reform Action Items For
2014/2015
Reporting
Requirements
For Plan Sponsors and
Employers
For Plan Sponsors and
Employers
Requirements
Due By:Due By:
Reporting
Form M-1 filing due by multiple employer
welfare arrangements. Entities filing Form
M-1 are required to file Form 5500 (due
by last day of 7th month following plan
year)MAR 1
Section 6055 and/or 6056 reports to IRS.
2015 calendar year information reporting
due 1st quarter 2016 (Due March 31 if
filing electronically)
JAN 31
FEB 28
Additional Form W-2 Reporting:
Aggregate cost of health coverage
reported for previous calendar year
NOV 15
Transitional Reinsurance Reporting:
Number of covered lives due by plan
sponsors or insurers by November 15 to
HHS
NOV
2014
Controlling Health Plan (CHP): Self-funded
health plans must obtain a Health Plan
Identifier (HPID) by application through
CMS; large plans ($5 mil or larger) by Nov
5, 2014, small plans by Nov 5, 2015
Controlling Health Plan (CHP) must certify
that it is in compliance with standards for
electronic transactionsDEC
2015
JUL 31
PCOR fees are paid annually in
connection with IRS Form 720, Quarterly
Federal Excise Tax Return. Fee: $1 per
covered life (indexed) for plan years
ending before 10/1/13; $2 per covered
life (indexed) for plan years ending after
9/30/13 and before 10/1/14. For self
funded plans, Form 720 is due by July 31st
of the calendar year following the plan
year end; for insured plans, the insurer files
by July 31 following end of policy year