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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
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
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
Employer Health Reform Action Items For
2014/2015
Are You A Large Employer for 2015?
99
100
No
Yes
Due By: Due By:
Are You A Large Employer for 2016?
49
50
No
Yes
#1BenefitsConsulting
firm
CBIZ is the only benefits consulting firm
that brings a fully-integrated service
platform to its clients, providing subject-
matter expertise in Employee Benefits,
Payroll, Actuarial, Accounting, Tax, and
Compensation.
The information contained herein is not intended to be legal, accounting, or other professional advice, nor are these comments
directed to specific situations. The information contained herein is provided as general guidance and may be affected by changes in
law or regulation. The information contained herein is not intended to replace or substitute for accounting or other professional advice.
Attorneys or tax advisors must be consulted for assistance in specific situations. This information is provided as-is, with no warranties of
any kind. CBIZ shall not be liable for any damages whatsoever in connection with its use and assumes no obligation to inform the reader
of any changes in laws or other factors that could affect the information contained herein. As required by U.S. Treasury rules, we inform
you that, unless expressly stated otherwise, any U.S. federal tax advice contained herein is not intended or written to be used, and
cannot be used, by any person for the purpose of avoiding any penalties that may be imposed by the Internal Revenue Service.
Begin counting full-time and full-time
equivalent employees to determine
whether Employer Shared Responsibility will
apply. Use any consecutive 6-month
period in 2014 for counting employee hoursBegin
Now
© Copyright 2014 – CBIZ, Inc. NYSE Listed: CBIZ All Rights Reserved
Employer employing 100+ Employees:
Subject to employer shared responsibility
mandate beginning 1/1/15 (transition relief
available for non-calendar year plans)2015
Employers employing 50 to 99 full-time
employees become subject to shared
responsibility mandate on plan anniversary
occurring in 2016, if certain criteria are
certified2016
For more information, contact your local CBIZ
Advisor or call out toll-free help line 1-800-ASK-
CBIZ (1-800-275-2249)

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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
  • 4. Employer Health Reform Action Items For 2014/2015 Are You A Large Employer for 2015? 99 100 No Yes Due By: Due By: Are You A Large Employer for 2016? 49 50 No Yes #1BenefitsConsulting firm CBIZ is the only benefits consulting firm that brings a fully-integrated service platform to its clients, providing subject- matter expertise in Employee Benefits, Payroll, Actuarial, Accounting, Tax, and Compensation. The information contained herein is not intended to be legal, accounting, or other professional advice, nor are these comments directed to specific situations. The information contained herein is provided as general guidance and may be affected by changes in law or regulation. The information contained herein is not intended to replace or substitute for accounting or other professional advice. Attorneys or tax advisors must be consulted for assistance in specific situations. This information is provided as-is, with no warranties of any kind. CBIZ shall not be liable for any damages whatsoever in connection with its use and assumes no obligation to inform the reader of any changes in laws or other factors that could affect the information contained herein. As required by U.S. Treasury rules, we inform you that, unless expressly stated otherwise, any U.S. federal tax advice contained herein is not intended or written to be used, and cannot be used, by any person for the purpose of avoiding any penalties that may be imposed by the Internal Revenue Service. Begin counting full-time and full-time equivalent employees to determine whether Employer Shared Responsibility will apply. Use any consecutive 6-month period in 2014 for counting employee hoursBegin Now © Copyright 2014 – CBIZ, Inc. NYSE Listed: CBIZ All Rights Reserved Employer employing 100+ Employees: Subject to employer shared responsibility mandate beginning 1/1/15 (transition relief available for non-calendar year plans)2015 Employers employing 50 to 99 full-time employees become subject to shared responsibility mandate on plan anniversary occurring in 2016, if certain criteria are certified2016 For more information, contact your local CBIZ Advisor or call out toll-free help line 1-800-ASK- CBIZ (1-800-275-2249)