Just around the corner is an immediate deadline imposed by the Affordable Care Act (ACA), November 5, 2014. Fortunately that is not a difficult one to fulfill. The requirement is to get a "health plan identifier number," or HPID. Small plans -- those through which less than $5 million flows in a year, have a November 5, 2015 deadline. The requirement pertains to the government's desire to simplify HIPAA compliance monitoring. For that, you will need to consult with an accounting professional for details.

1. Toll Free: 877.880.4477
Phone: 281.880.6525
Get Ready for Upcoming Affordable
Care Act Compliance Deadlines
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2. Just around the corner is an immediate deadline imposed by the Affordable
Care Act (ACA), November 5, 2014. Fortunately that is not a difficult one to
fulfill. The requirement is to get a "health plan identifier number," or HPID.
Small plans -- those through which less than $5 million flows in a year, have a
November 5, 2015 deadline. The requirement pertains to the government's
desire to simplify HIPAA compliance monitoring. For that, you will need to
consult with an accounting professional for details.
www.hrp.net
»

3. Ten days later, November 15, 2014, is the deadline for self-insured employers
to submit an enrollment count to the Department of Health and Human
Services in order to establish your 2014 Transitional Reinsurance Fee. The fee
for this year is $63 per covered employee. Payment of the fee is due January
15, 2015. Note: If your health plan is fully insured, your carrier will take care
of this. Data can be submitted via www.pay.gov
Self-insured employers have until July 31 next year to pay a similar, but much
less expensive fee, which is the Patient-Centered Outcomes Research
Institute Trust Fund fee. The new per-capita fee is $2.08, and is based on
average plan enrollment over the course of the plan year. That rate applies to
plan years ending after September 30, 2014 and before October 1, 2015.
www.hrp.net
»
»

4. Pay-or-Play Bite Begins
As is widely known, next year is when most "non-grandfathered" employers
with at least 100 full-time equivalent (FTE) employees will be subject to
penalties if they have not complied with the employer mandate. In theory,
they were subject to the mandate this year, but will not pay a penalty for
ignoring it. If your company is in the 50-99 FTE bracket, you have a reprieve
until 2016.
www.hrp.net

5. A quick ACA refresher on this topic: For 2015, you're required to offer
coverage to 70 percent of your employees and their dependents, or pay the
penalty. That jumps to 95 percent in 2016 and thereafter.
Alternatively, you'll be subject to a penalty if your plan does provide
"minimum essential coverage," but that coverage is unaffordable. This is
based on the employee's share of the cost in relationship to household
income, or based on paying less than 60 percent of the plan's value.
Note: If your plan year doesn't coincide with the calendar year, you might not
be subject to the mandate until the first day of your 2015 plan year.
www.hrp.net

6. New Out-of-Pocket Maximums
Another limit on the financial burden employees can be asked to bear has
been adjusted upward -- by about 1.6 percent -- for 2015. Specifically, the
maximum out-of-pocket limits, combining employee deductibles, co-pays and
coinsurance, cannot exceed $6,600 for employee-only and $13,200 for family
coverage. Ceilings on deductibles for high-deductible health plans offered in
conjunction with a health savings account rose to $6,450 and $12,900,
respectively. If you have a separate pharmacy benefit plan, employee
maximum costs under that plan must be added to the basic health plan in
calculating maximum employee cost-sharing.
www.hrp.net

7. Data Roundup
Most self-insured health plan sponsors will need to start collecting certain
health plan data in 2015 to report to the IRS in 2016. These requirements are
governed by two Internal Revenue Code sections: 6055, pertaining to
minimum essential coverage, and 6056, which addresses "large plan
reporting" (large being at least 50 FTEs; self-insured employers of any size are
required to supply minimum essential coverage). IRS regulations have been
issued describing these requirements in detail. Draft copies of the reporting
forms also are being circulated.
The IRS forms require Taxpayer Identification Numbers (TINs, which are
typically Social Security numbers) not only for employees but also for covered
spouses and dependents. The sooner you start chasing down those numbers,
the better. The IRS will give employers a one-year pass if they can't gather all
the TINs for the minimum essential coverage form, so long as they have
made a "good faith effort" to get them.
www.hrp.net

8. One More Thing
Remember the 2013 Windsor v. United States decision requiring ERISA plans
to accord the same spousal benefits to same-sex spouses as opposite-sex
couples? Although the ruling wasn't specific on the point, it is considered
advisable to have a plan amendment reflecting that ruling -- if anything else
in your plan documents would suggest otherwise -- by the end of 2014.
www.hrp.net

9. 14550 Torrey Chase Blvd., Ste. 360 Houston, TX 77014 USA
Toll Free
Phone
Fax
:
:
:
877.880.4477
281.880.6525
281.866.9426
E-mail : info@hrp.net
www.hrp.net

10. 14550 Torrey Chase Blvd., Ste. 360 Houston, TX 77014 USA
Toll Free
Phone
Fax
:
:
:
877.880.4477
281.880.6525
281.866.9426
E-mail : info@hrp.net
www.hrp.net