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PPACA’S REQUIREMENTS: 2015-2018

REQUIREMENT

DESCRIPTION

EFFECTIVE DATE

EMPLOYER/PLAN SPONSOR RESPONSIBILITY

BAS RESPONSIBILITY

Individual mandate penalty increase

The individual mandate penalty effective in 2014 will increase by $325 or 2% of household income over filing limit.

2015

· No employer role

· No BAS role

Individual mandate penalty increase

The individual mandate penalty increase will increase from $325 or 2% of household income over filing limit to $695 or 2% of household income over filing threshold.

2016

· No employer role

· No BAS role

Large employers may participate in exchanges

The exchanges created in 2014, may now allow large employers to purchase insurance through the exchanges.  Large employers are defined as employers with more than 100 employees.

2017

Determine if at you qualify as a large employer, and if you wish to participate in the HIE. Regulatory Guidance Pending

· No BAS role

40% excise (Cadillac) tax on employer-sponsored health benefits over a certain threshold

Any employer that sponsors high cost coverage must notify the IRS and its insurer or plan administrator (if self-funded) of associated tax liabilities. PPACA has a 40% excise tax for plans that are deemed high cost coverages. Regulatory guidance pending

2018

Employers should review their plans to determine if the plan(s) qualifies as a Cadillac plan. Regulatory Guidance Pending

· No BAS role



PPACA EMPLOYER NOTICE REQUIREMENTS

PPACA Requirement

Effective Date

Notice or Notification Description

Does Requirement Apply to Grandfathered and Non- Grandfathered Plans?

Disclosure of Grandfather Status

First Plan Year beginning on or after September 23, 2010

A Grandfathered Plan must include a statement that the Plan believes it is a Grandfathered Plan in any materials describing benefits to alert participants that certain consumer protections may not apply. Model language is available from the DOL, at  www.dol.gov/ebsa/healthreform

Grandfathered Plans Only

Information on State Exchanges Section 1512 of PPACA

No later than 3/1/2013 for existing employees; beginning 3/1/2013 for new hires

AFTER AN INITIAL DELAY WHICH POSTPONED THIS REQUIREMENT OF 3/1/2013, THE DOL ANNOUNCED ON 5/8/2013 THAT THIS REQUIREMENT WILL TAKE EFFECT ON 10/1/2013.

Notice from the plan must inform employees about how the Exchanges operate and the circumstances under which they may receive coverage Regulatory guidance pending

Yes

Reporting on the Employer mandate Section 1514 of PPACA

Calendar year 2014

Reporting Requirements have been delayed till 2015 with the first reports due in early 2016.

Regulations have been added under Sections 6055 and 6056 of the IRS that impose new reporting requirements for Group Health Plans which include reports to the IRS and detailed statements to participants.

Regulatory guidance pending

Yes

Cadillac Plans Section 9001 of PPACA

Calendar year 2018

Any employer that sponsors high cost coverage must notify the IRS and its insurer or plan administrator (if self-funded) of associated tax liabilities. PPACA has a 40% excise tax for plans that are deemed high cost coverages. Regulatory guidance pending

Yes

Revised 07/17/2013

Publications prepared by BAS are intended to inform our clients of information relating to Group Health Plans.  The publications are based on information available at the time they are prepared and should not be relied upon to provide either legal or tax advice.

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