THANK
YOU TO EVERYONE WHO ATTENDED OUR FEBRUARY SEMINARS ON HEALTHCARE REFORM FOR
EMPLOYERS. GREAT TURNOUT and EXCELLENT Q&A. MORE TO COME...
As many of you know, I
was one of the delegates from Charleston in Washington, DC last week to attend
the Capitol Conference on Health Insurance. Overall the experience was
very positive and I look forward to sharing the latest insurance news with our
clients.
Below are some updated Snapshots of hot items
regarding Healthcare Reform. ALSO, please use our presentation as a complete point of
reference. It is available on our website and stays up to date. Or contact
me and lets schedule a time to discuss.
Snapshots from DC Insurance Conference
and HC Reform. -
1. The Value of a good
Insurance Broker/Agent - Having a knowledgeable and pro-active
broker/agent will be very important for employers and individuals. This
is complicated information and a mistake or poor strategy will prove costly to
employers and individuals alike.
THE TIME TO PREPARE IS
NOW!
2. The Essential
Health benefits (EHB) for
individuals and small groups is likely to change to higher deductibles as the
Administration is realizing that the original $2,000 deductible max is
likely to cause an undue strain on premiums. Qualified plans will still
need to have at least 60% actuarial value. And there will be out of
pocket caps for all plans.
3. 3:1 age
ratio - unless
this ruling is reversed (LIBERTY ACT - encourage your representative
to vote for repeal) , young healthy people(less than age 40) should expect to
see "rate shock" as their rates will not be allowed to be more than 3
times less than age 64 rates. This will affect small group and individual
policies.
4. Calculating 50
Full Time Equivalent (FTE) employees for purposes of the Penalties - You should use a
consecutive 6 month period in 2013 to determine if you have 50
FTE.. Seasonal employees working less than 120 days for 2013 can be
excluded. Employers should be keeping track of these numbers as of January 1,
2013 for 2014 calculation.
5. Who must be offered Coverage? Employees
who work 30 hours or more per week based on a 3 to 12 month measurement period.
Employers need to offer coverage but employees will continue to have the
right to waive coverage.
6. Employer
Penalties if employee waives coverage - If a large group employer
offers qualified and affordable coverage to at least 95% of all Full time
employees and employee waives coverage and seeks a subsidy, the employer
will not be liable for the penalty/ fine. There will be an IRS triggering
process "e-mailed" to the employer if a waived employee tries to
collect subsidy so the employer can confirm they offered qualified and
affordable coverage and avoid the penalty. I recommend all employers keep
on file waivers for proof of coverage offer.
7. Premium Contribution
Discrimination - Can't
discriminate in favor of highly compensated employees. Premium
contributions based on job classification or tenure should be clearly defined
by employer....though expect changes and more clarification especially with the
9.5% affordability clause.
8. 9.5%
affordability clause -
Employees that are forced to spend more than 9.5% of their
individual gross income (BOX 1 on W-2) will be eligible for exchange
subsidy. The 9.5% rule is based on employee only premium. If they
are spending less than 9.5% of premium and have a qualified employer plan they
will not be eligible for subsidy.
9. Common Ownership - Common
ownership rules apply when calculating 50 FTE to determine if a penalty applies
for not offering qualified, affordable coverage. Common ownership can't
be defined based on EIN alone. The ruling is based on "Controlled
Group" status and can be defined by parent/subsidiary companies or sister
companies. I will ask all groups to confirm their controlled group status
with a qualified CPA. I can refer one if needed.
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Thank You, Marshall
Thank You, Marshall