Watch Yvonne Frame, Client Executive at Marsh & McLennan Agency and Nancy Sansom, VP-Marketing at PeopleMatter to learn how the Affordable Care Act will impact the multi-location service industry. Whether you are in foodservice, hospitality or retail, changes are fast approaching in 2014 that will affect you. You won’t want to miss out on this free webinar to learn:
- Learn the latest changes in the ACA, including what’s been pushed and what you need to do now
- Hear exactly how control groups work and how to calculate your total costs under them
- Get the rundown on when benefit plans, rules and fees go into effect, and how much they’ll run you
-Watch a live demo of our online and mobile tools that make it easy to keep your labor costs under control
5. In place
requirements!• Maintain compliance with existing
provisions!
• Grandfathered (GF) plans must:!
• Annually monitor degree of changes
against requirements!
• Fulfill annual notification
requirements!
Overview!
6. In place
requirements!• Maintain compliance with existing
provisions!
• Grandfathered (GF) plans must:!
• Annually monitor degree of changes
against requirements!
• Fulfill annual notification
requirements!
• Plans losing GF status must:!
• Implement non-GF status
requirements !
• 100% preventive care coverage!
• Appeals processes!
• Provider selection/referral rules!
• Out of network employer coverage!
Overview!
7. 2012—2013!
continue to implement:!
• Summaries of Benefits and Coverage!
• W-2 reporting!
• $2,500 health care FSA limit!
• Coverage of additional women’s preventive
care!
• Effectiveness research fees!
• Medicare tax increase for high earners!
• Medicare retiree Rx subsidy elimination!
• Medical loss ratio rebate distribution (insured
plans)!
• Exchange notifications for employees!
Overview!
8. 2014 and beyond !
develop strategies for:!
• Individual mandate!
• Employer mandate (2015)!
• Health insurance exchanges &
Medicaid expansion!
• 90-day waiting period limit!
• New health plan fees!
• Required notices & reporting!
• No essential benefit or !
pre-ex limits!
!
• Limits on out of network (Non-
GF) & deductible (Non-GF
small group)!
• Coverage for clinical trial-
related services (Non-GF)!
• Insured non-discrimination
rules (date?)!
• Cadillac tax (2018)!
• Auto-enrollment (date?)!
Overview!
9. October 1, 2013!
January 1, 2014!
Upcoming Important Dates!
January 1, 2015 !
Overview!
• Employers must distribute
Marketplace notices by this
date!
• Marketplace opens!
• Marketplace coverage is
effective!
• Individual mandate in
effect!
• Employer mandate in effect!
10. Employer Mandate: Delayed!
Overview!
• Requirement to offer coverage to full-time employees !
• Minimum value requirement for coverage offered!
• Affordable contribution requirement!
• Employer information reporting to IRS!
What was delayed to January 1, 2015?!
January 1, 2015 !
• Employer mandate in effect!
11. Employer Mandate: Delayed!
January 1, 2015 !
Overview!
• Employer mandate in effect!
• Insurance marketplaces & expanded Medicaid!
• Individual mandate & marketplace subsidies!
• 90-day waiting period limit!
• PCORI, transitional reinsurance & health insurer fees!
• Notice of coverage options & Summary of Benefit Coverage (SBCs) w/ plan value statement!
• Various plan changes!
• Wellness incentive increase!
What was NOT delayed?!
13. Public"
• State-provided platform for individuals to purchase !
health coverage!
• Federal exchange will be set up if state does not by 2014!
• Small Business (1–100) can purchase exchange coverage!
• Large Employers (100+) can purchase exchange coverage in
2017!
Private"
• Marketplace with health only or core and supplemental
product offerings across many benefits and services!
• Exchange sponsor stock products and manages end-to-end
consumer experience!
Insurance Exchanges!
Pu!
Pr!
14. Insurance Exchanges!
Default to Federal Exchange (26)!
Declared State-based Exchange (18)!
Planning for Partnership Exchange (7)!
Source: Kaiser Family Foundation http://www.statehealthfacts.org/comparemaptable.jsp?ind=962&cat=17, accessed 3/11/2013!
IL
NY
PA NJ
DE
MD
WV
MT
WA
ID
OR
TX
ND
MN
WI
MI
VA
NC
SC
GA
FL
ALMS
LA
NM
AZ
WY
SD
NE
CO
KS
OK
IA
MO
AR
IN
KY
TN
HI
AK
CA
NV
UT
ME
NH
VT
CT RI
MA
DC
OH
16. If no employer plan is offered and 1 or more Full-Time (FT)
employee receives the exchange coverage tax credit subsidy,
employer pays penalty of $2,000/FT employee (first 30 FT
employees excluded from penalty)!
If employer plan is offered but is offered to less than 95% of FT
employees or is not offered to employees’ children, rules outlined
above apply. !
If coverage is offered to 95%+ of FT employees and children but is
“insufficient” or “unaffordable” and 1 or more FT employee receives
the exchange coverage tax credit subsidy, employer pays penalty of
$3,000/FT employee receiving subsidy (or $2,000 per FT employee,
if less)!
Pay!$
Play!
or!
Employer Mandate!
17. How do you determine group size?
Beginning in 2015,
companies with more than
50 Full-Time Equivalent
(FTE) employees are
subject to the Pay or Play
mandates/penalties.!
Group Size!
FTE (>30 hrs/week)!
23!
PT Employees
(Aggregate Hours !
worked per month / 120)!
3,800/120 = 23!
23 + 23 = 46!
Employer Mandate!
18. “Look Back” Period!
3 –12 months (you choose)!
Admin.
Period!
up to 90 days!
Standard Stability Period!
no less than 6 months or length of !
“Look Back” period!
How do you determine full-time status of part-time
and seasonal workers?!
If employee averages 30+ hours/
week during measurement period,
employee must be considered full-
time for subsequent stability period;
if not, employee will be considered
not full-time for the stability period!
Employer may use
administrative
period up to 90
days between look
back and stability
periods to conduct
enrollment!
Employer may choose a look-back
measurement period of 3 to 12
months and a stability period of no
less than 6 months or the length of
the measurement period, if greater!
Employer Mandate!
19. Pay!$! Play!
– Penalties!
– Compensation increases
due to loss of benefits?!
– Auto Enrollment!
– Individual Mandate!
– Expanded eligibility!
– Medicaid expansion!
Employer Mandate!
or!
21. The entire Controlled
Group is considered for
application of !
the Pay or Play rules!
Rule 1!
Controlled Groups!
1!
B Corp.!
10 FTEs!
A Corp.!
3 FTEs!
C Corp.!
25 FTEs!
D Corp.!
35 FTEs!
With over 50 FTEsin the ControlledGroup, Pay or Playapplies!
80% ownership!
80% ownership!80% ownership!
22. If the entire Controlled Group has over 50
FTEs, the “Pay” penalty applies to each
entity separately. !
Rule 2a!2!
$2,000!
$8,000!
$22,000!
$34,000!
Penalty!
x $2,000!
$66,000!
A Corp.!
B Corp.!
C Corp.!
D Corp.!
1!
7!
22!
33!
FT Employees!
0!
3!
11!
16!
FT Credit!
63! 30!Total!
1!
4!
11!
17!
Net FT Employees!
33!
=!
=!
=!
=!
Controlled Groups!
23. If the entire Controlled
Group has over 50
FTEs, the “Play” penalty
applies to each entity
separately. !
C Corp.!
0 FT EEs receives
subsidized exchange
coverage!
D Corp.!
7 FT EEs receives
subsidized exchange
coverage = $21,000!
B Corp.!
7 FT EEs receives subsidized
exchange coverage = $3,000!
A Corp.!
0 FT EEs receives
subsidized exchange
coverage!
Controlled Groups!
Rule 2b!2!
25. Pay or Play Strategies!
Determine health
benefits not key to
retention/
recruitment!
Pay!
$!
$2,000 penalty
on all FT
employees
(minus 1st 30)!
Pay adjustment!
to keep
employees
whole!
Determine
health benefits
matter!
Play!
Engage
employees to
manage health!
Aggressively
manage plan on
a long term
basis!
You first should decide how important offering competitive
healthcare benefits is to your business – and if it is important,
then decide how to effectively manage annual employer costs!
$
/
26. Employers Likely Actions Regarding Employees Working 30+ Hrs/Week!
6%
18%
32%
45%
Make all employees working 30+ hours/week eligible for full-time employee plan(s)!
Make no change and pay penalty as necessary!
Add a lower-cost plan for employees that work fewer than 40 hours/week!
Change workforce strategy so that fewer employees work 30+ hours/week!
Pay or Play Strategies!$
/
Source: Mercer Survey of Employer-Sponsored Health Plans 2011!
27. Health management
Implement results-driven
population health management
program!
Offset cost increases
Increase dependent tier
contributions to offset cost
increases resulting from single tier
contribution reduction and new
opt-ins due to individual mandate!
Salary-based contribution
Create salary-based contribution,
i.e. lower contributions only for
those potentially eligible for
penalty-generating subsidies
(income below 400% of FPL)!
Value plans
Offer a 60% value plan and
position current plan as a buy-up
option!
Decrease staff levels!
Decrease number of staff working
30+ hours per week (reduce hours
of those currently working just over
30 hrs/week)!
Alternative funding
Consider alternative funding
options (e.g., ASO, level funding,
captives, etc.)!
Pay or Play Strategies!$
/
28. Create additional classes for employees
working between 30 & current FTE level
that are FT health care only!
Monitor employees that are expected to
work less than 30 hours/week!
Under ACA some of labor pool and part time employees
will be considered FTEs for health insurance in 2015!
Strategies!
Pay or Play Strategies!$
/
Reset status for full-time employees to 30
hours per week!
30. Employers Likely Actions Regarding Employees Working 30+ Hrs/Week!
6%
18%
32%
45%
Make all employees working 30+ hours/week eligible for full-time employee plan(s)!
Make no change and pay penalty as necessary!
Add a lower-cost plan for employees that work fewer than 40 hours/week!
Change workforce strategy so that fewer employees work 30+ hours/week!
Source: Mercer Survey of Employer-Sponsored Health Plans 2011!
Workforce Management Impact!
31. Workforce Management Impact!
Employees @ !
40 hrs / week!300!
38% !
Increase in people to
hire, train and schedule!
Employees @ !
29 hrs / week!414!
How many more workers
do I have to manage if I
keep my employees
working less than 30 hours
per week? !
Part-Time Workforce!
How many more workers?
32. • Find and evaluate more people!
• Interview more people!
• Perform more background/drug/
motor vehicle checks!
!
!
More Hiring!
• Manage more I-9s!
• File more tax credit paperwork!
• Complete more orientation
sessions!
• Complete more new hire
paperwork and other tasks!
More Onboarding! 38%+"
Workforce Management Impact!
41. • More people to train on process
changes, product line changes,
etc.!
• Difficulty keeping the attention of
workers with multiple jobs!
!
!
More Ongoing Training!
38%+"
Workforce Management Impact!
More Onboarding. . . !
More Hiring. . . !
42.
43. • More time-off requests!
• Shift changes and swaps!
• Increased complexity in worker
availability!
More Scheduling Tasks!
38%+"
Workforce Management Impact!
More Ongoing Training. . . !
More Onboarding. . . !
More Hiring. . . !
46. Create additional classes for employees
working between 30 & current FTE level
that are FT health care only!
Reset status for full-time employees to 30
hours per week!
Monitor employees that are expected to
work less than 30 hours/week!
Under ACA some of labor pool and part time employees
will be considered FTEs for health insurance in 2015!
Strategies!
Workforce Management Impact!
47. “Look Back” Period!
3 –12 months (you choose)!
Admin.
Period!
up to 90 days!
Standard Stability Period!
no less than 6 months or length of !
“Look Back” period!
How do you determine full-time status of part-time
and seasonal workers?!
If employee averages 30+ hours/
week during measurement period,
employee must be considered full-
time for subsequent stability period;
if not, employee will be considered
not full-time for the stability period!
Employer may use
administrative
period up to 90
days between look
back and stability
periods to conduct
enrollment!
Employer may choose a look-back
measurement period of 3 to 12
months and a stability period of no
less than 6 months or the length of
the measurement period, if greater!
Workforce Management Impact!
54. September 12, 2013"
®
Your ACA Questions Answered!
What Restaurants Need to Do Now to Stay Profitable under the
Affordable Care Act!
(877) 300-6222"
info@peoplematter.com"yvonne.frame@marshmc.com"