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Benefits Buzz April 2014

Employer Mandate Delayed for Medium-sized Employers

A major provision of the Affordable Care Act was delayed in February, when the U.S. Treasury Department announced that pay or play rules will not take effect for some medium-sized employers until 2016.

Under the final regulations, applicable large employers (ALEs) that have fewer than 100 full-time employees will generally have an additional year to comply with the pay or play rules. ALEs with 100 or more full-time employees must still comply with the pay or play rules starting in 2015.

To qualify for this delay, an ALE must provide documentation stating that it meets the following eligibility conditions:

  1. The employer must employ at least 50 full-time employees (including full-time equivalent employees (FTEs)) but fewer than 100 full-time employees (including FTEs) on business days during 2014;
  2. During the period beginning on Feb. 9, 2014, and ending on Dec. 31, 2014, the employer may not reduce the size of its workforce or the overall hours of service of its employees in order to satisfy the workforce size condition; and
  3. During the coverage maintenance period (that is, the period ending Dec. 31, 2015, or the last day of the plan year that begins in 2015), the employer may not eliminate or reduce the health coverage it offered as of Feb. 9, 2014.For more information on the employer mandate delay, please contact TMC Employee Benefits Group today.

Reporting Rules Finalized for Employers and Issuers

The Affordable Care Act created new reporting requirements for employers regarding health plans they offer (or do not offer) to their employees.

On March 5, the IRS finalized rules pertaining to reporting requirements under Internal Revenue Code Sections 6055 and 6056.

The first final rule, on the Section 6055 reporting requirements, requires health insurance issuers, self-insured health plan sponsors, government agencies that administer government-sponsored health insurance programs and any other entity that provides minimum essential coverage to report information on that coverage to the IRS and covered individuals.

The second final rule, on the Section 6056 reporting requirements, requires employers with at least 50 full-time employees to report to the IRS and to covered individuals information on the health coverage offered to full-time employees.

The final regulations apply for calendar years beginning after Dec. 31, 2014.

DID YOU KNOW?

Under the Affordable Care Act, cost-sharing limits for health plans are updated annually. On March 5, the Department of Health and Human Services published rules establishing the cost-sharing limits for 2015.

The annual deductible for a health plan in the small group market for 2015 may not exceed $2,050 for self-only coverage and $4,100 for family coverage (although an exception allows higher deductibles in some cases), and the annual out-of-pocket maximum cannot exceed $6,600 for self-only coverage and $13,200 for family coverage.

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