As you’ve been reading, the Patient Protection and Affordable Care Act (PPACA) becomes fully effective in 2014, when the employer mandate and public exchanges go into effect. That means that the rest of this year is about preparing. This EBN article provides six compliance deadlines which we’ve summarized below.
- “Preparing for the 2014 employer mandate: The employer mandate applies only to large employers. Whether an employer is defined as large under PPACA (generally companies with 50 or more employees) depends on the number of its full-time equivalent employees. Companies with 50 or more full-time workers (averaging at least 30 hours per week) must offer minimum health care coverage that is affordable.” So, this year is the time to determine if you, or your employer, is “subject to the mandate.” If an employer “offer(s) coverage in 2014, the coverage must meet the minimum value standards and the contributions the employer requires of employees cannot be so high the coverage is unaffordable relative to the employee’s household income,” says Jean C. Hemphill, practice leader of Ballard Spahr‘s health care group. Please reach out to us if you need help determining the affordability of your (or your employer’s) plan.
- Public exchanges: EBN writes that “Employers are required to provide employees with notice alerting them of the existence of public insurance exchanges. It is thought that the government will issue a model notice for this purpose.” Please let us know if you need a sample of this notice. The exchange for California is Covered Califonia.
- Waiting periods: Per EBN “Another design-related issue employers must factor into their plans is that under PPACA, waiting periods for health care coverage cannot exceed 90 days. The 90-day period begins when the employee is otherwise eligible for coverage. Employers with a high-turnover workforce that currently have long waiting periods will have to shorten them. If an employer requires employees to work a minimum number of hours to qualify for coverage, it may need to monitor workers’ timesheets in 2013 to determine if and when coverage needs to be offered in 2014; this may be complicated for seasonal employees and other employees with variable hours.” Please contact us for help in determining if your policy meets the qualifications for providing coverage.
- Pre-existing and non-discrimination prohibitions: There are new rules in 2014, but “employers can expect notice and guidance well before implementation.” We’ll share those rules in a blog post as soon as we receive them.
- Wellness programs: The Act “includes rules that prohibit plans from discriminating against individuals based on a range of health-related factors.” Check with your insurer, or us, for help in determining if your 2013 plan will be in compliance in 2014.
- Upcoming fees and taxes: “Patient-Centered Outcomes Research Institute, established by PPACA, will collect and publish information about clinical effectiveness of treatments for patients. It will be paid for through fees assessed against insurers and self-funded plans equal to $2 ($1 in the first year) per covered life. The assessment will last seven years and eventually be adjusted for inflation. Employers with self-funded plans will need to report and pay these fees starting in July 2013.” Wow, that’s coming up really fast!
Well, that’s a lot to take in…good thing we all have a few months to get ready! And we’re happy to help you in any way we can…we look forward to speaking with you soon!