Holiday season commences this week. So begin the shopping lists, party planning and a generally festive feeling in the air. As it all comes to an end, most of us will wrap up with a grand new year’s celebration to joyfully welcome 2015.
For those who work with health plans, however, the mention of the turning of this new year might be met with a wince or shudder—The dawning of the new year may be shadowed by the compliance challenges ahead. Several Affordable Care Act (ACA) requirements begin, or need preparation, in 2015. We have the resources you need to make sure you are ready, keeping thoughts of ACA far from your New Year’s festivities.
As we’ve experienced over the past two plus years, ACA developments are rather unpredictable and often require additional guidance. In anticipation of the ongoing challenge, the International Foundation built two comprehensive resources to help you throughout your ACA implementation journey. ACA University is a virtual learning center with a full library of resources and regular live events. And ACA Central is your source for up-to-the-minute news, regulatory updates and compliance guidance.
Let’s walk through the coming requirements in the new year and point you to resources that you’ll find in ACA Central.
2015 Compliance Requirements Employer Shared Responsibility
For large employers (100 or more full-time employees) the employer mandate is here. Originally set to begin in 2014, but delayed until 2015, large employers face penalties if they do not offer minimum essential coverage to their employees and dependents and if any of their employees receive a subsidy to obtain coverage through a public health insurance exchange.IRS ReportingFour IRS reporting requirements have due dates in 2016 but require collecting information in 2015. Below are links to the forms and instructions:
Instructions for Forms 1094-B and 1095-B
Instructions for Forms 1094-C and 1095-C
Form 1094-B Transmittal of Health Coverage Information Returns
Form 1094-C Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
Form 1095-B Health Coverage 2015
Form 1095-C Employer-Provided Health Insurance Offer and Coverage
2015 Fee Requirement
ACA’s Transitional Reinsurance Program requires that all health insurance issuers, self-insured group health plans, and third-party administrators on their behalf, make contributions to support reinsurance payments to individual market issuers that cover individuals with high medical costs. 2015 is the first year that this transitional reinsurance fee payment is due.
Not in 2015, but time to start planning . . .
The Cadillac Tax rules have not been published (effective date is January 1, 2018). Because of the anticipated plan design changes expected, many plans are starting to prepare now. 25% of organizations responding to the International Foundation’s 2014 Employer-Sponsored Health Care: ACA’s Impact have already started to redesign their primary health plan to avoid triggering the 2018 excise tax.
Leery of continuing changes to ACA rulings? Keep an eye on ACA Central for updated information. Follow @ifebp on Twitter for alerts as new content is added. As for topics of conversation during your New Year’s celebration, I suggest steering clear of ACA compliance.