1) Distribution of Marketplace Notice to Employees; 2) 90-day Waiting Period; 3) Individual Shared Responsibility- Final Regulations; 4) Employer Appeals in Marketplace Eligibility Determinations; 5) Small Business Tax Credit; 6) Preventive Care - Health Saving Accounts; and 7) Internal Claims, Appeals and External Review: Providing Culturally and Linguistically Appropriate Notices
Health Reform Bulletin 116 Year End Wrap Up 12-29-15Daniel Michels
The most recent CBIZ Health Reform Bulletin: Year-End Wrap Up (HRB 116). This issue includes specific information and guidance on:
1. Late breaking development, IRS delays new Affordable Care Act's (ACA) reporting and disclosure obligations!
2. On December 18, 2015 Consolidate Appropriations Act, 2016, and the Protecting Americans from Tax Hikes (PATH) Act of 2015 (H. R. 2029; now Public Law No. 114-113) were signed by the President, and amend several provisions of the Affordable Care Act.
3. The IRS Issued guidance relating to ACA implementation
4. Year-End Reminders
Health Reform Bulletin: Small Business Health Options Program (SHOP) UpdatesCBIZ MHM, LLC
One of the components of the Affordable Care Act is the Small Business Health Options Program (SHOP). The SHOP is the marketplace, sometimes referred to as "exchange," specific to small employers. Find out the status of your state's marketplace in this document.
How can you smooth the healthcare reform transition? Learn about the mandates currently in place, the mandates that are coming in the near future, what employers need to do, and what employees need to do. Participants can also ask specific questions about how healthcare reform may impact their organization.
Health Reform Bulletin 116 Year End Wrap Up 12-29-15Daniel Michels
The most recent CBIZ Health Reform Bulletin: Year-End Wrap Up (HRB 116). This issue includes specific information and guidance on:
1. Late breaking development, IRS delays new Affordable Care Act's (ACA) reporting and disclosure obligations!
2. On December 18, 2015 Consolidate Appropriations Act, 2016, and the Protecting Americans from Tax Hikes (PATH) Act of 2015 (H. R. 2029; now Public Law No. 114-113) were signed by the President, and amend several provisions of the Affordable Care Act.
3. The IRS Issued guidance relating to ACA implementation
4. Year-End Reminders
Health Reform Bulletin: Small Business Health Options Program (SHOP) UpdatesCBIZ MHM, LLC
One of the components of the Affordable Care Act is the Small Business Health Options Program (SHOP). The SHOP is the marketplace, sometimes referred to as "exchange," specific to small employers. Find out the status of your state's marketplace in this document.
How can you smooth the healthcare reform transition? Learn about the mandates currently in place, the mandates that are coming in the near future, what employers need to do, and what employees need to do. Participants can also ask specific questions about how healthcare reform may impact their organization.
Health Reform Bulletin Oct, 2015 - Amendments to the small employer definitio...CBIZ, Inc.
The latest Health Reform Bulletin is here! This bulletin is chock full of information from a new law that amends the definition of small employer, finalized ACA reporting forms 1094 and 105 and adjusted PCORI fees and much more. Check out some more in-depth information above.
Health Reform Bulletin 124 | Qualified Small Employer HRAs and Year-end Remin...CBIZ, Inc.
In December 13, 2016, President Obama signed the 21st Century Cures Act (H.R. 34). In part, this law re-establishes the ability of small employers, those not subject to the Affordable Care Act’s employer shared responsibility provisions, to provide their employees a stand-alone health reimbursement arrangement (HRA), known as a “qualified small employer HRA”.
Reporting Requirements for Every Business
At the minimum, the IRS requires every employer to document, track and prove their employer status. Get the complete break down of requirements for employee counts from 0 to 100+.
Learn Critical Terms You Need to Know
From Form 1095-C to Safe Harbor Rules, we break down the most frequently used ACA terms employers will encounter.
Get A Blueprint for Measurement Periods
Break down the who, what, and how of ACA reporting to learn how to measure data for new hires and current employees.
Break Down the Form 1095-C by Sections
Get a clear understanding of the Form 1095-C and navigate the tougher sections to know what information you’ll need to file to avoid costly penalties.
Group health plans can require qualified beneficiaries to pay for COBRA continuation coverage, although plan sponsors can choose to provide continuation coverage at reduced or no cost.
The maximum amount charged to qualified beneficiaries cannot exceed 102 percent of the plan’s total cost of coverage. The cost amount is based on the cost of coverage for similarly situated individuals who have not incurred a qualifying event. For qualified beneficiaries receiving the 11-month disability extension, the premium for those additional months may be increased to 150 percent of the plan's total cost of coverage...
In early July, the Department of Treasury announced it is delaying a key mandate of the Affordable Care Act: what's known as the 'Pay or Play' mandate. While pushing pause on this mandate gives large employers another year to prepare, we strongly advise businesses not to wait to start making strategic decisions. For more information, contact Fraser Trebilcock Senior Health Care and Business Attorney Mike James at mjames@fraserlawfirm.com or 517.377.0823. You can also find more information at www.milhealthlaws.com.
The Marketplace: What Every Employer Should Knowbenefitexpress
This presentation helps assist employers in talking to their employees about the Marketplace. It will cover all you need to know about the Marketplace.
Temporary Employees and the Employer Mandatebenefitexpress
This presentation reviews - when temporary employees become your employees, the factors the government uses to determine employment status, the steps you can take to avoid these employees becoming your employees, and consequences under Health Care Reform if it is determined that they are your employees.
Cadillac Tax for Employers 101 - How to Avoid Penalties?benefitexpress
This webinar covers: what coverages are subject to the tax, how the excise tax is determined, what adjustments will be available in determining the tax, and who collects the tax.
This webinar covers a basic review of the requirements under ERISA, including: what is an ERISA benefit, what documentation requirements have to be met, what disclosure requirements have to be met, what reporting requirements need to be met, what is a fiduciary, and what are other requirements.
This presentation covers how Medicare affects employer health coverage in: Providing opt out amounts | Paying for Medicare for active employees | Electing COBRA
Health Care Reform Legislative Brief
2013 Compliance Checklist
In light of the Supreme Court's June 28, 2012, decision to uphold the health care reform law, or Affordable Care Act (ACA), employers must continue to comply with ACA mandates that are currently in effect.
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One of the components of the Affordable Care Act is the Small Business Health Options Program (SHOP). The SHOP is the marketplace, sometimes referred to as “exchange”, specific to small employers.
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The government is winding up 2015 and ringing in 2016 with a bang. The final HRB of 2015 will keep you abreast of the various changes that occurred at the end of the year.
Health Reform Bulletin Oct, 2015 - Amendments to the small employer definitio...CBIZ, Inc.
The latest Health Reform Bulletin is here! This bulletin is chock full of information from a new law that amends the definition of small employer, finalized ACA reporting forms 1094 and 105 and adjusted PCORI fees and much more. Check out some more in-depth information above.
Health Reform Bulletin 124 | Qualified Small Employer HRAs and Year-end Remin...CBIZ, Inc.
In December 13, 2016, President Obama signed the 21st Century Cures Act (H.R. 34). In part, this law re-establishes the ability of small employers, those not subject to the Affordable Care Act’s employer shared responsibility provisions, to provide their employees a stand-alone health reimbursement arrangement (HRA), known as a “qualified small employer HRA”.
Reporting Requirements for Every Business
At the minimum, the IRS requires every employer to document, track and prove their employer status. Get the complete break down of requirements for employee counts from 0 to 100+.
Learn Critical Terms You Need to Know
From Form 1095-C to Safe Harbor Rules, we break down the most frequently used ACA terms employers will encounter.
Get A Blueprint for Measurement Periods
Break down the who, what, and how of ACA reporting to learn how to measure data for new hires and current employees.
Break Down the Form 1095-C by Sections
Get a clear understanding of the Form 1095-C and navigate the tougher sections to know what information you’ll need to file to avoid costly penalties.
Group health plans can require qualified beneficiaries to pay for COBRA continuation coverage, although plan sponsors can choose to provide continuation coverage at reduced or no cost.
The maximum amount charged to qualified beneficiaries cannot exceed 102 percent of the plan’s total cost of coverage. The cost amount is based on the cost of coverage for similarly situated individuals who have not incurred a qualifying event. For qualified beneficiaries receiving the 11-month disability extension, the premium for those additional months may be increased to 150 percent of the plan's total cost of coverage...
In early July, the Department of Treasury announced it is delaying a key mandate of the Affordable Care Act: what's known as the 'Pay or Play' mandate. While pushing pause on this mandate gives large employers another year to prepare, we strongly advise businesses not to wait to start making strategic decisions. For more information, contact Fraser Trebilcock Senior Health Care and Business Attorney Mike James at mjames@fraserlawfirm.com or 517.377.0823. You can also find more information at www.milhealthlaws.com.
The Marketplace: What Every Employer Should Knowbenefitexpress
This presentation helps assist employers in talking to their employees about the Marketplace. It will cover all you need to know about the Marketplace.
Temporary Employees and the Employer Mandatebenefitexpress
This presentation reviews - when temporary employees become your employees, the factors the government uses to determine employment status, the steps you can take to avoid these employees becoming your employees, and consequences under Health Care Reform if it is determined that they are your employees.
Cadillac Tax for Employers 101 - How to Avoid Penalties?benefitexpress
This webinar covers: what coverages are subject to the tax, how the excise tax is determined, what adjustments will be available in determining the tax, and who collects the tax.
This webinar covers a basic review of the requirements under ERISA, including: what is an ERISA benefit, what documentation requirements have to be met, what disclosure requirements have to be met, what reporting requirements need to be met, what is a fiduciary, and what are other requirements.
This presentation covers how Medicare affects employer health coverage in: Providing opt out amounts | Paying for Medicare for active employees | Electing COBRA
Health Care Reform Legislative Brief
2013 Compliance Checklist
In light of the Supreme Court's June 28, 2012, decision to uphold the health care reform law, or Affordable Care Act (ACA), employers must continue to comply with ACA mandates that are currently in effect.
Health Care Reform - Small Business Health Options Program (SHOP) UpdatesCBIZ, Inc.
One of the components of the Affordable Care Act is the Small Business Health Options Program (SHOP). The SHOP is the marketplace, sometimes referred to as “exchange”, specific to small employers.
Health Reform Bulletin 116 | Year-End Wrap Up Dec. 29, 2015CBIZ, Inc.
The government is winding up 2015 and ringing in 2016 with a bang. The final HRB of 2015 will keep you abreast of the various changes that occurred at the end of the year.
Health Reform Bulletin – IRS PronouncementsCBIZ, Inc.
Information on 1) Cafeteria Plan Status Change Events, 2) Employment Status Change Proposals to Employer Shared Responsibility Rules, 3) Increase in PCOR Fees, and Final Excepted Benefit Regulations. Recently, the Internal Revenue Service (IRS) released three pronouncements relating to the Affordable Care Act (ACA). In addition, final regulations have been issued relating to certain excepted health benefits.
Health Reform Bulletin 131 | The ACA Remains The Law of The LandCBIZ, Inc.
As has been covered extensively in the press, Congress went on its summer recess without repealing, replacing or modifying the Affordable Care Act. What this means for employers is that it is “business as usual”, including all reporting obligations, as more fully described below. So where does health care reform stand at this point? The answer to this question is far from clear.
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INGUARD Benefits Division presentation on the Affordable Care Act final rules, how they affect group benefits, and the responsibilities of employers in the coming years. Includes best practices for updating your employee benefits and how to stay in compliance with the ACA regulations.
In this issue, new SFE&G partner Theresa Borzelli and guest co-author Mary B. Anderson of ERISAdiagnostics Inc. discuss the timely issue of shared responsibility regarding health coverage (Pay or Play). Mychelle Holloway explains why your record keeper requests certain information from the plan sponsor. Also read about SES' recent promotions and new hires
Health Reform: Interim Guidance on Expatriate Plans; Updates on ACA Reportin...CBIZ, Inc.
This Health Care Reform Bulletin provides information on the following topics:
a. Interim Guidance on Expatriate Health Coverage
b. Updates on Section 6055/6056 Reporting
i. Revised and Increased Reporting Penalties
ii. E-filing requirements for Employers
c. Final Rules: Preventive Services
d. Reminder on PCOR Fees and Transitional Reinsurance
i. Checklist for PCOR and Transitional Reinsurance Fee
Staffscapes, Inc. is a Human Resources Outsourcing firm that specializes in HR, Payroll & Benefits. We recently presented this slide show to a group of Colorado Small Business Owners and Managers and are sharing it with the general public today.
Get ready for the Affordable Care Act. The light you see is the oncoming train!
Lot's of things happening, not too many answers and it will take a few years to flesh it all out.
Health Reform - Additional IRS Approaches to the Cadillac Tax; Transitional R...CBIZ, Inc.
Guidance on:
1. Additional IRS Approaches to Cadillac Tax. On July 30, 2015, the IRS released a second pronouncement (IRS Notice 2015-52), which like the first, does not carry the weight of the law or regulation, but rather is an effort to test the waters to see how the law should be formulated. The new guidance expands the discussion with regard to identifying taxpayers liable for the excise tax, employer aggregation, allocation of the tax, payment of the applicable tax and determining the cost of applicable coverage.
2. Transitional Reinsurance Fee Process for 2015 Benefit Year. In preparation for reporting and paying the transitional reinsurance fees for the 2015 benefit year, the Centers for Medicare and Medicaid services released an overview of the process and procedures
3. State Innovation Waivers. The Affordable Care Act includes a provision that takes effect in 2017 which would allow a state to apply for an innovation waiver; pursuant to which the state could be relieved from certain aspects of the ACA.
4. Applicability of ACA’s Employer Shared Responsibility Provisions. On July 31, 2015, President Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (H.R. 3236); now Public Law 114-41). This law provides that for purposes of determining whether an employer is an applicable large employer with regard to employee enrollment in minimum essential health coverage under an eligible employer sponsored plan, individuals covered for medical care under TRICARE or the Veterans Administration are not counted. In addition, a recent lawsuit challenged the applicability of the ACA’s employer shared responsibility mandate to a Native American tribe.
Affordable Care Act (ACA) Commonly Used TerminologyInfinisource
The Affordable Care Act and its terminology are overwhelming - where does one begin to understand it all? We’ve compiled a glossary of ACA terminology to help you through the maze.
Similar to Health Reform Bulletin: Implementation Guidance & ACA Updates (20)
Affordable Care Act (ACA) Commonly Used Terminology
Health Reform Bulletin: Implementation Guidance & ACA Updates
1. CBIZ Health Reform Bulletin
September 11, 2013 – HRB 81 Page 1
Subject: Guidance and Updates: 1) Distribution of Marketplace Notice; 2) 90-day Waiting
Period; 3) Individual Shared Responsibility; 4) Employer Appeals in Marketplace
Eligibility Determinations; 5) Small Business Tax Credit; 6) Preventive Care – Health
Saving Accounts; and 7) Internal Claims, Appeals and External Review: Providing
Culturally and Linguistically Appropriate Notices
Date: September 11, 2013
As October 1st
fast approaches, the government is busy issuing a plethora of guidance. October 1st
is an important date in that it is the date the marketplace, sometimes referred to exchange, is open
for business. What this means is that individuals and small businesses can begin to enroll in health
coverage through these newly implemented vehicles. Coverage purchased through these
marketplaces will become effective January 1, 2014, at the earliest.
DISTRIBUTION OF MARKETPLACE NOTICE TO EMPLOYEES
One of the most immediate matters for employers to attend to is distribution of the market place
notice (see CBIZ HRB October 1st Deadline Reminder: Notice to Employees of Marketplace
Coverage Options, 8/28/13). The DOL’s Employee Benefit Security Administration has just issued a
new set of Frequently Asked Questions relevant to this notice.
Specifically, this sub-regulatory guidance affirms that a third party can distribute the marketplace
notice on behalf of the employer. This might make sense, for example, for a multi-employer plan to
distribute the notice to individuals covered by the multi-employer plan. If an employer’s employees
participate in a multi-employer plan, a notice distributed by the multi-employer plan would satisfy the
employer’s obligation. However, it is very important for the employer to remember that it must
provide the notice to all of its other employees who do not receive the notice from the multi-employer
plan.
Another example might be a third party administrator distributing the notice to all individuals covered
by the plan it administers. Again, the employer must remember that the marketplace notice must be
provided to all employees; therefore, the employer would be obligated in this situation to distribute
the notice to those who do not receive it from a third party.
90-DAY WAITING PERIOD
On the first plan anniversary occurring on or after January 1, 2014, the maximum waiting period that
can be imposed by any plan is 90 days (see CBIZ HRBs 90 Day Wait and Other Updates (3/26/13)
and Guidance Issued Relating to 90-day Waiting Period and Defining Full-time Employee (9/4/12)).
A newly issued FAQ affirms that substantive eligibility provisions that are not directed at avoiding
the 90-day restriction are permissible. The example used in the FAQ is a multi-employer plan that
defines eligibility based on hours worked in a quarter for one or more employers. Based on these
2. CBIZ Health Reform Bulletin
September 11, 2013 – HRB 81 Page 2
hours worked, the individual would qualify for coverage for the subsequent quarter. This FAQ
affirms that this type of eligibility provision is permissible.
INDIVIDUAL SHARED RESPONSIBILITY – FINAL REGULATIONS
The ACA imposes an individual shared responsibility requirement. This requirement mandates that
beginning January 1, 2014, virtually all individuals residing in the U.S. must maintain a minimum
level of coverage, or risk a shared responsibility payment (see CBIZ HRB, Individual Minimum
Essential Coverage, 2/6/13).
On August 30, 2013, the IRS and Treasury Department issued final regulations, together with a
Fact Sheet, relating to the individual shared responsibility requirement. Following are highlights of
these regulations.
Employer Coverage Qualifies and MEC. While these regulations do not have significant
importance for employers, they do affirm that generally employer health coverage, whether
insured or self-funded, will constitute minimum essential coverage (MEC). Similarly, COBRA
and retiree coverage qualifies as MEC as long as the individual is actually covered.
Third Party Coverage. Of great interest to employers who use third party coverage, the
preamble to the regulations affirms that third party coverage, such as coverage through a
professional employer organization (PEO), a leasing company, or by a multi-employer plan,
qualifies as MEC. The preamble does go to great lengths to affirm that this in no way implicates
who the employer is. In other words, the employer-employee relationship is governed by
existing law and contractual relationship, and is not impacted by this determination.
Liability for Dependent Coverage. These regulations require the individual to maintain
coverage for him/herself and his/her dependents. For purposes of these regulations,
dependents are those as defined by IRC Section 152, including the taxpayer’s biological child,
step child, adopted child or foster child, up to age 26, as well as a dependent who meets the
definition of qualifying child or qualifying relative of the taxpayer. The individual would be liable
for the shared responsibility payment attributable to the dependent's lack of coverage
regardless of whether the taxpayer claims the individual as a dependent on a Federal income
tax return for the taxable year.
Transition Relief. There is transitional relief for 2014 for individuals whose employers maintain
non-calendar year plan years (see the Transition Relief discussion in the CBIZ HRB, Employer
Shared Responsibility Reporting Requirements Delayed and Final Exchange Regulations,
7/3/13). If the individual is eligible for an employer plan for which the anniversary is different
from the calendar year, the individual will not be subject to individual shared responsibility
requirement until the plan anniversary occurring on or after January 1, 2014.
EMPLOYER APPEALS IN MARKETPLACE ELIGIBILITY DETERMINATIONS
On August 28, 2013, the HHS” Center for Consumer Information & Insurance Oversight issued final
rules, together with a Fact Sheet, relating to exchange (marketplace) program standards. Of
particular note, these rules address how individuals and employers can appeal eligibility decisions
rendered by the marketplaces, including determinations rendered through the small business health
options program (SHOP). This would include instances in which an individual’s eligibility for
premium tax credits or cost-sharing reductions is denied, or a determination that an employer’s plan
does not provide minimum essential coverage that meets both minimum value and affordability
standards.
3. CBIZ Health Reform Bulletin
September 11, 2013 – HRB 81 Page 3
SMALL BUSINESS TAX CREDIT (SBTC) UPDATES
The Affordable Care Act includes a small employer health insurance tax credit that has been in
effect for several years now (see CBIZ HRB Additional Guidelines to the Small Business Tax Credit
(12/22/10) and The Small Business Health Care Tax Credit (5/20/10)). On August 26, 2013, the
IRS issued proposed regulations relating to this tax credit.
Following are highlight of these proposed regulations. These changes begin January 1, 2014.
Eligible Employers. Employers entitled to the credit remain the same. To be eligible, the
employer must employ fewer than 25 full-time equivalent employees whose average annual
wages are less than $50,000 (adjusted for inflation beginning in 2014). In addition, the small
employer must cover at least 50% of the cost of single (not family) health care coverage for
each employee.
Qualifying Coverage. The credit is only available for qualified health plan (QHP) coverage
purchased through the Small Business Health Options Program (SHOP) and is only available
for 2 consecutive years. The small employer does not relinquish its right to the credit by not
taking it immediately. In other words, the employer could decide to claim the credit in 2017 and
2018, even though it may have qualified for the credit earlier.
Amount of Credit. For tax years beginning in 2014 and beyond, the maximum credit will
increase from 35% to 50% of premiums paid by small business employer, and from 25% to 35%
paid by small tax-exempt employers.
Uniform Contributions. To be eligible for the credit the employer must make a uniform
contribution toward health coverage. The regulations give several examples of how to
determine a uniform percentage:
Example1. An eligible small employer (Employer) offers a QHP on a SHOP Exchange, Plan
A, which uses composite billing. The premiums for Plan A are $5,000 per year for self-only
coverage, and $10,000 for family coverage. Employees can elect self-only or family
coverage under Plan A. Employer pays $3,000 (60% of the premium) toward self-only
coverage under Plan A and $6,000 (60% of the premium) toward family coverage under
Plan A. In this example, the Employer's contributions of 60% of the premium for each tier of
coverage satisfy the uniform percentage requirement.
Example 2. Same scenario as Example 1, except that Employer pays $3,000 (60% of the
premium) for each employee electing self-only coverage under Plan A and pays $3,000
(30% of the premium) for each employee electing family coverage under Plan A. In this
example, the Employer's contributions of 60% of the premium toward self-only coverage and
the same dollar amount toward the premium for family coverage satisfy the uniform
percentage requirement, even though the percentage is not the same.
Transition Relief. If a small employer health plan year is different from a taxable year, the
employer would be able to take the full 50% credit in 2014 even if it does not offer QHP
coverage though a SHOP until its plan anniversary occurring in 2014, as long as:
1. As of August 26, 2013, the small employer offers coverage in a plan year that begins on
a date other than the first day of its taxable year;
4. CBIZ Health Reform Bulletin
September 11, 2013 – HRB 81 Page 4
2. The employer offers coverage during the period before the first day of the plan year
beginning in 2014 that would have qualified the employer for the credit under the rules
otherwise applicable to the period before January 1, 2014; and
3. The employer begins offering coverage through a SHOP as of the first day of its plan
year that begins in 2014.
Additional information relating to the SBTC, including a tax credit estimator, FAQs, and forms for
claiming the credit can be found on the IRS’ dedicated webpage.
PREVENTIVE CARE – HEALTH SAVING ACCOUNTS
On September 9, 2013, the IRS issued Notice 2013-57 affirming that a qualified high deductible
health plan (HDHP) used in conjunction with a health savings account (HSA) remains HSA-qualified
despite providing first dollar coverage for preventive services mandated by ACA. As background,
an HSA must be paired with a qualified HDHP. The HDHP can only reimburse expenses after a
certain minimum statutory deductible has been satisfied. The ACA requires that non-grandfathered
health plans cover preventive services without any cost-sharing, including the imposition of a
deductible. This ruling affirms that the preventive services mandated by the ACA can be covered
by the qualified HDHP used in conjunction with an HSA without requiring satisfaction of a
deductible.
INTERNAL CLAIMS, APPEALS AND EXTERNAL REVIEW: UPDATE ON PROVIDING CULTURALLY AND
LINGUISTICALLY APPROPRIATE NOTICES
The ACA requires that documents provided to individuals in a claim denial and external review
process be provided in a culturally and linguistically appropriate manner, i.e., in the appropriate
language of the claimant (see CBIZ HRB, Modifications to Claims and Appeals, and External
Review Processes, 7/11/11). The determination of what language to provide information to
claimants is based on the number of non-English speakers residing in a particular geographic area.
The threshold percentage for group health plans requires language appropriate notices when at
least 10% of a county’s population speaks a particular non-English language and who do not speak
English “very well”. The HHS’ Center for Consumer Information & Insurance Oversight has recently
issued updated step-by-step instructions for calculating the 10% threshold in order to provide the
appropriate documents in the appropriate languages.
About the Author: Karen R. McLeese is Vice President of Employee Benefit Regulatory Affairs for CBIZ
Benefits & Insurance Services, Inc., a division of CBIZ, Inc. She serves as in-house counsel, with particular
emphasis on monitoring and interpreting state and federal employee benefits law. Ms. McLeese is based in the
CBIZ Leawood, Kansas office.
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.