the aca & your organization: what you need to know - BerryDunn PDF
Preview the aca & your organization: what you need to know - BerryDunn
April 25, 2013 THE ACA & YOUR ORGANIZATION: WHAT YOU NEED TO KNOW crossagency.com | berrydunn.com ACA LIKELY HERE TO STAY • Law passed on March 23, 2010 • Supreme Court – weighs in on June 28, 2012 Authority to extend individual mandate comes from Congress’s power to tax • Presidential Elections on November 6, 2012 President Obama Re-Elected 2 PLANS SUBJECT TO HEALTH CARE REFORM • Health plan rules generally apply to group health plan coverage • Exceptions • Excepted benefits • Accident or disability income coverage • Separate dental and vision plans • Liability insurance • Some FSAs • Retiree-only health plans • Group health plans covering fewer than 2 employees 3 PROVISIONS ALREADY IN PLACE • Small employer tax credit • Dependent coverage to age 26 • No lifetime limits/restrictions on annual limits • No rescissions • No pre-existing condition exclusions for children • No cost-sharing for preventive care services (non-GF plans) • Appeals process changes (non-GF plans) • No reimbursement for OTC medicine or drugs (without a prescription) Exception is insulin 4 TODAY’S TOPICS Form W-2 Summary of Medical Loss Limits on FSA reporting of Benefits & Ratio Rebates contributions health insurance Coverage (2012) (2013) (2012 ) (2012) Transitional Health Insurance Small Business PCOR fees Reinsurance Provider Fee Heath Care Tax (2012 – 2019) Fees (2014 ) Credit (ongoing) (2014 – 2016) Exchange Individual Employer play Notices Mandate and or pay rules (2013 ) Credit (2014) (2014) 5 FORM W-2 REPORTING FOR VALUE OF HEALTH CARE Effective with 2012 tax year (Forms issued in January 2013) • Reporting is for informational purposes only Benefits continue to be tax-free • Must report the value of “applicable employer sponsored coverage” • Only applies to Large Employers for now 6 ACA IMPACT IN 2012 Medical Loss Ratio (MLR) Rebates • Applies to calendar years beginning on or after January 1, 2011 Applies to fully insured plans • Based on insurer’s MLR – not plan specific • MLR Threshold: • Large Plans (>100 benefits eligible employees) = 85% • Small Plans (100 or less benefits eligible employees) = 80% 7 SUMMARY OF BENEFITS & COVERAGE (SBC) • Simple and concise explanation of benefits Applies to GF and non-GF plans • Model template and guidance available • Special rules specify when SBC must be provided • Does not replace other required plan documents 8 NEW MEDICAL FSA LIMIT FOR 2013 Annual limit on Cafeteria Plan Health FSA Contributions Limit will be $2,500 per plan year (as indexed) • A plan limit; not an individual limit • For employee deferrals; not for employer contributions Effective for Plan Years beginning on or after 1/01/2013 Don’t forget to amend plans on or before 12/31/2014! 9 PATIENT CENTER OUTCOMES RESEARCH (PCOR) FEE – IRC §4376 • Applies to insurers and sponsors of self-insured plans (including HRAs and some Medical FSAs) • The fee is: 2012 • $1 x Average # of covered lives 2013 • $2 x Average # of covered lives 2014 – 2019 • $2 (indexed) • Applies to Plan Years ending after 10/01/2012 • Reportable and payable by means of IRS Form 720 • Filing due date is 7/31 for all Plan Years ending in preceding calendar year 10
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