Jan. 30, 2014 – Now that 2014 is here, we’d like to summarize what to expect from the Accountable Care Act this year.
Insurance Exchanges: Health care purchasing exchanges must be operational in every state.
New Health Coverage Options Begin: Millions of Americans have been signing up for health insurance plans since the exchanges opened on October 1, 2013. People who have been successful in signing up can now take advantage of new health plan options and federal subsides.
Individual Health Insurance Mandates: If you are not enrolled in a Qualified Health Plan in either the individual market, or through an employer or other group plan by March 1, 2014, you can expect to pay a penalty of $95 or 1% of your income, whichever is higher, unless you qualify for an exception.
Insurance Subsidies: Premium tax credits and cost sharing reductions kick in for those individuals who are eligible.
Medicaid Expansion Begins: As a result of the Supreme Court ruling, the Medicaid program will be expanded in 2014. As many as 3.9 million additional low income people will now have access to the program.
Annual or Lifetime Limits: Health plans can no longer include annual or lifetime limits on benefits.
Small Business Tax Credits: Small businesses are eligible to apply for a small business tax credit which would help them purchase health insurance for their employees. It is projected that a very small number of small businesses will qualify since the credits can only be used if they buy SHOP exchange coverage which is limited in 2014.
Individual and Businesses will see additional taxes and fees: The new ACA National Premium Tax will cost consumers, fully insured individuals, and group health insurance an estimated $8 billion in 2014 and is expected to reach $14.3 billion by 2018.
Group Health Care Waiting Periods: Employer health plans can only have waiting periods of up to a maximum of 90 days and is effective on the plan year effective date.
Cost Sharing Limits: All group health plans may not have out of pocket costs that exceed the annual Health Savings Account contribution maximum.
Wellness Program Discounts: Employers may now offer a discount of up to 30% for employee participation in an employer sponsored wellness program.
More information regarding these ACA provisions can be found on MBPA’s Health Care Reform Connect website.
https://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.png00michbusinesshttps://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.pngmichbusiness2014-01-27 17:00:002015-10-08 00:00:00Affordable Care Act – What to Expect in 2014
Question: In 2014, will an employee’s nonworking spouse be eligible for premium credits or subsidies on the Exchange if (1) the employee’s employer does not offer medical coverage to employee’s spouse or (2) the employer offers medical coverage to the employee spouse’s but does not pay for any portion of the premium for such spouse’s coverage?
Answer: Under Treasury Regulations Section 1.36B-2(c)(3)(v)(A)(2), an eligible employer-sponsored plan will be affordable for related individuals (family members) if the cost of self-only coverage does not exceed 9.5% of the employee’s household income. In other words, for purposes of determining whether family members are eligible for premium tax credits, the cost of family coverage is not taken into account-all that matters is whether the cost of self-only coverage is affordable to the employee.
Therefore. if an employer offers coverage to the employee’s spouse, but does not pay for any part of his or her premium, he or she will not eligible for credits and subsidies if the coverage offered to the employee is affordable.
If an employer does not offer coverage to the employee’s spouse, he or she would be eligible for credits and subsidies depending on the family’s household income.
https://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.png00michbusinesshttps://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.pngmichbusiness2013-11-27 09:06:152015-10-08 00:00:00Health Reform Questions – Family Member Eligibility for Premium Credits
Nov. 26, 2013 – The Department of Health and Human Services (HHS) announced on November 22, 2013 that individuals will have an extra week to enroll in coverage effective January 1, 2014.
The delay is to account for technical issues experienced with the website healthcare.gov. The original December 15th deadline for individuals applying for coverage effective January 1st has been extended to December 23rd.
The delay does not change the 2014 open enrollment period which began October 1, 2013 and runs through March 31, 2014.
The extension will allow the federally run Marketplace more time to prepare for the next open enrollment period and allow insurers to make appropriate rate decisions.
https://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.png00michbusinesshttps://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.pngmichbusiness2013-11-27 08:59:272015-10-08 00:00:00Federally-Facilitated Individual Marketplace Enrollment Period Extended One Week
Nov. 26, 2013 – In the words of actress Lauren Bacall, “Standing still is the fastest way of moving backward in a rapidly changing world.” Businesses today face many challenges in their efforts to keep moving forward. One of the most pressing, especially for companies with their eyes on the future, is to offer a strong employee health and wellness package. Let’s take a look at some of the top promising trends we’re seeing when it comes to corporate health and wellness.
Shifts in insurance coverage
The Affordable Care Act goes into full swing in 2014, which will provide nearly all Americans with affordable, comprehensive health insurance. Past policies in insurance coverage had been shifting more of the burden of health care costs onto the backs of employees. This practice left many workers facing the painful choice of paying their rent or visiting their physician. The new trend offers comprehensive plans that include general wellness, behavioral health, medications, maternity, disease management, and emergency care, while including free preventive care.
Custom designed health and wellness plans
Businesses today are better able to take control of the health and wellness resources they offer employees. Savvy leaders are interested in creating strategies that help control costs, measure effectiveness, and incentivize results. Wellness programs, incentives, and health reimbursement accounts that go beyond the basics of conventional health plans are all strategies to accomplish this. Wellness programs are growing outside of the HR department to include leadership, operations, and health providers for more effective engagement and better outcomes. This enables better control and consistency while allowing agility to adjust health plans or third party administrators.
Offering wellness incentives for participation and results
During a time when health care costs are skyrocketing, offering incentives is an excellent way to inspire people to change unhealthy lifestyle and behavioral patterns that will ultimately drive the costs of providing health care higher. Of course, any “outcome” based incentives must be compatible with appropriate laws such as the Americans with Disabilities Act, the Genetic Information Nondiscrimination Act, and the Health Insurance Portability and Accountability Act. Keep in mind, allowances for premium differentials will increase to 30 percent of insurance expenses for compliant wellness programs and to 50 percent for tobacco cessation in 2013 as a result of the Affordable Care Act.
Results-driven rewards for health providers
Many health plans are beginning to offer rewards and limits to health providers based upon efficiency and costs. The Affordable Care Act also instituted a 6-year tax, beginning in 2012 for the purpose of examining and improving medical effectiveness. Providers must offer appropriate health assessments, screenings, and examinations. More importantly, they are going to be held accountable for managing diseases such as high blood pressure, asthma, diabetes, high cholesterol, heart disease, and COPD. Rewards will integrate economic and medical best practices.
Renewed focus on primary and preventive care
The high costs of preventive health in the past left many people skipping it completely. Now the focus has shifted and preventive care, including focus on vaccines, health kiosks, and retail health clinics, is a critical part of the overall efforts to lower costs. Increasing attention toward prevention has positioned primary care physicians as champions to promote and provide proactive care. Although the physician-patient relationship is being emphasized, the shortage of primary care physicians will further increase the role of health and wellness professionals to educate, evaluate and refer treatment. Prevention, after all, remains the best cure.
Transparency in costs
One of the most often cited complaints about health care in the past has been the lack of transparency when it comes to prices. Without transparency, purchasers cannot make responsible decisions about affordability of care and the idea of healthy competition is out the window. Today, providers are offering cost estimators, comparison tools, mobile apps, and countless other tools to keep consumers informed. ??
Improvements in technology and communication
Not only does technology help diagnostics and treatment, but it also can help improve communication. Tablets now fit in physician lab coats to allow convenient e-prescribing and reporting. By 2014, electronic medical records will be required; this allows a completely streamlined approach to the patient experience. Further, standards will be implemented to reduce data silos, integrate records, and reduce redundancy. In addition, the complicated amount of changes will require extra communication to aid delivery and understanding, particularly to a rapidly aging population.
The future of corporate health and wellness is here. Businesses that fail to move their strategy forward stand to be left behind by those that do.
Scott Foster is president of Wellco, a leading Wellness ROI provider based in Michigan. Foster has developed award-winning, results-oriented strategies to fix wellness programs and measurably improve organizational health costs and conditions. He can be reached at scott.foster@wellcocorp.com.
This article first appeared in Corp! magazine online March 7, 2013.
https://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.png00michbusinesshttps://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.pngmichbusiness2013-11-25 17:00:002015-10-08 00:00:00Don’t let Your Health and Wellness Plan Fall Behind
Nov. 26, 2013 – The concept of “affordable” coverage comes up frequently when trying to navigate the complex rules under the Patient Protection and Affordable Care Act (“PPACA”). While it is a defined term, it has different meanings depending on whether you are trying to understand compliance with the employer shared responsibility provisions, determine whether an individual will be eligible for subsidized marketplace/exchange coverage, or understand the exemptions from the individual mandate penalties.
Employer Shared Responsibility Provisions
For an Applicable Large Employer to avoid employer shared responsibility penalties beginning in 2015, the employer must provide “affordable”, minimum value coverage to at least 95% of its full-time workforce and their dependent children to age 26. In this context, the term “affordable” means that the cost of self-only coverage (regardless of the coverage level in which the individual is actually enrolled) does not exceed 9.5% of the individual’s household income (the modified adjusted gross income of the employee and any members of the employee’s family, including spouse and dependents, who are required to file an income tax return). Instead of using an employee’s household income, the IRS permits employers to use one of the following safe-harbors:
• W-2 Wages: Coverage will be deemed affordable so long as the cost to employees for self-only coverage does not exceed 9.5% of the employee’s W-2 wages with that employer. (Note: Many employers do not prefer this method as it does not take into consideration any pre-tax contributions to benefit plans and, therefore, could actually produce a lower base to determine affordability.)
• Rate-of-Pay: Coverage will be deemed affordable so long as the cost to employees for self-only coverage does not exceed 9.5% of the employee’s monthly “rate-of-pay” which is calculated by taking the employee’s hourly rate multiplied by 130.
• Federal Poverty Line: Coverage will be deemed affordable so long as the cost to employees for self-only coverage does not exceed 9.5% of the annual federal poverty line for a single individual ($11,490 for 2013).
If an employer offers multiple levels of coverage, affordability can be based upon the lowest level of coverage that provides minimum value in accordance with applicable regulations.
It is also important to note that while in order to avoid employer shared responsibility penalties in 2015 and beyond the employer must also offer coverage to the dependent children (until age 26) of its full-time employees, the cost of the coverage for those dependents does not have to be “affordable”. In other words, an employer just has to offer the coverage to dependents and can charge any amount for dependent coverage, even 100% employee paid, and not trigger penalties.
Eligibility for Exchange Subsidies
Beginning in 2014, U.S. citizens and legal residents in families with household incomes between 100% and 400% of the federal poverty level for the individual’s family size, and who are not offered affordable, minimum value coverage through an employer, are eligible to receive a premium subsidy to reduce the cost of purchasing health coverage on the exchange. For these purposes, “affordability” is based on the cost for self-only coverage (regardless of the level of coverage in which the employee is actually enrolled) not exceeding 9.5% of the individual’s household income. The method used by the applicable employer to determine affordability for employer shared responsibility purposes does not determine affordability for purposes of exchange subsidies.
Individual Mandate Penalties
Beginning in 2014, PPACA requires U.S. citizens and legal residents to maintain minimum essential coverage for themselves and any nonexempt family members. Failure to maintain such coverage could subject individuals to penalties unless the individuals are exempt from this requirement. One category of exempt individuals are those that do not have an affordable health coverage option available to them. For these purposes, “affordability” means that the cost of coverage does not exceed 8% of the individual’s household income based on either (1) the self-only premium under an eligible employer-sponsored plan, or (2) the self-only premium for the single lowest cost Bronze level plan available on the exchange serving the area in which the individual resides.
*This article is not intended to give legal advice. It is comprised of general information. Employers facing specific issues should seek the assistance of legal counsel.
Kristi R. Gauthier is a senior attorney in Clark Hill’s Birmingham office and concentrates her practice in Employee Benefits Law. Kristi has represented clients in a wide variety of employee benefits issues involving health and welfare benefits, as well as retirement plans. Kristi is admitted to practice in the State of Michigan, the U.S. District Court for the Eastern District of Michigan, and the U.S. Sixth Circuit Court of Appeals. She also is active in the legal community with memberships in the American Bar Association, the State Bar of Michigan, and the Oakland County Bar Association where she is a member of the Employee Benefits Committee. Kristi also serves as a member of the Clark Hill Diversity and Inclusion Committee. Kristi has lectured on various employee benefits issues, including ERISA compliance, healthcare reform, COBRA, section 125 plans, 403(b) plans and IRS plan correction programs. Kristi is also a co-author of the ABA publication ERISA Survey of Federal Circuits. Kristi was named a “Rising Star” by Michigan Super Lawyers in 2011.
https://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.png00michbusinesshttps://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.pngmichbusiness2013-11-25 17:00:002015-10-08 00:00:00Determining ‘Affordability’ of Coverage under PPACA
On September 13, 2013, the Internal Revenue Service (IRS) issued Notice 2013-54 and the Department of Labor (DOL) issued Technical Release 2013-03. The two pieces of guidance are substantially identical and address many previously unanswered questions regarding how market reform and other provisions of the Affordable Care Act (Act) apply to health reimbursement arrangements (HRAs), including HRAs integrated with group health plans; health flexible spending arrangements (health FSAs); and employee assistance programs (EAPs).
The following series of questions and answers will review how these two pieces of guidance affect premium only plans (POPs) and health FSAs only in 2014.
1. In 2014, can an employer allow employees to pre-tax premiums for individual medical coverages purchased either inside or outside the public exchanges (marketplace)?
No. Code Section 125(f)(3), has been amended effective for taxable years beginning in 2014 to prohibit employees from purchasing coverage through a public Exchange on a pre-tax basis using the employer’s cafeteria plan (but, employees may still purchase coverage on a SHOP Exchange on a pre-tax basis using the employer’s cafeteria plan if the employer offers SHOP coverage to its employees).
For any individual health coverage purchased outside of the exchange, any pre-tax reimbursement of individual medical premiums under a POP would constitute an employer payment plan and would be disallowed.
Code Section 125 merely provides for the non-taxability of the choice between cash and pre-tax benefits. Code Section 125 does not provide the actual exclusion from employee income for employer-provided health coverage. That exclusion is reserved exclusively under Code Section 106. For tax (but not ERISA) purposes, amounts deducted from employees’ pay under a cafeteria plan election are treated as employer contributions. This is so because employee deferrals are made under a salary reduction agreement-the employee agrees to a reduction in salary in a specified amount and the employer agrees to contribute a like amount toward the purchase of qualified benefits (medical coverage, in this instance).
Therefore, any employee pre-tax contributions to a POP will be treated as employer funds and payment of premium by the employer with those funds (which are excluded from the employee’s gross income under Code Section 106) essentially becomes an employer payment plan. Employer payment plans for individual coverage fail Q&A-1 in Part III of IRS Notice 2013-54. This guidance provides that any employer payment plan, that reimburses employees for an employee’s substantiated individual insurance policy premiums must satisfy the market reforms for group health plans. However, the employer payment plan will fail to comply with the annual dollar limit prohibition because (1) an employer payment plan is considered to impose an annual limit up to the cost of the individual market coverage purchased through the arrangement, and (2) an employer payment plan cannot be integrated with any individual health insurance policy purchased under the arrangement.
2. Can an employee be reimbursed on a pre-tax basis under a POP for individual premiums for benefits other than medical coverage?
Yes. The above restrictions only apply to individual medical coverage. Under Proposed. Treasury Regulations Section 1.125-1(m)(1), it is possible to pre-tax individual premiums for dental, vision, disability, accidental death and dismemberment (AD&D), cancer insurance, hospital indemnity, and supplemental life insurance coverage, to name just a few. Please remember making a cafeteria plan available for individual policies (or paying for any portion of the premiums) raises issues under the Internal Revenue HIPAA, ERISA, COBRA, and other laws.
3. Which health FSAs are not subject to the Act and the market reforms in 2014?
IRS Notice makes clear that the Act’s market reform requirements do not apply to health FSAs that meet the “excepted benefit” definition.
A health FSA is considered an excepted benefit for a “class of participants” if the health FSA is a health FSA under Code Section 106(c)(2) and satisfies two conditions:
• Maximum Benefit Condition: The maximum benefit payable under the health FSA to any participant in the class for a year cannot exceed two times the employee’s salary reduction election under the health FSA for the year (or, if greater, the amount of the employee’s salary reduction election for the health FSA for the year, plus $500), as provided in Treasury Regulations Section 54.9831-1(c)(3)(v)(B); DOL Regulations Section 2590.732(c)(3)(v)(B); and HHS Regulations Section 146.145(c)(3)(v)(B); and
• Availability Condition: Other nonexcepted group health plan coverage (e.g., major medical coverage) must be made available for the year to the class of participants by reason of their employment, as provided in Treasury Regulations Section 54.9831-1(c)(3)(v)(A); DOL Regulations Section 2590.732(c)(3)(v)(A); and HHS Regulations Section146.145(c)(3)(v)(A).
Neither the regulations nor the preamble to the regulations explains what is meant by the term “class of participants.” The term appears to preclude a “participant-by-participant” approach to determining whether benefits under a health FSA are excepted benefits.
Examples of Health FSA Funding That Meet the Maximum Benefit Condition:
• A one-for-one employer match (employer $600, employee $600).
• An employer contribution of $500 or less (employer $500, employee $200).
Examples of Health FSA Funding That Do Not Meet the Maximum Benefit Condition:
• An employer contribution of more than $500, if the employee contributes $500 or less (employer $600, employee $400).
• An employer contribution in excess of a one-to-one match, if the employee contributes more than $500 (employer contributes $700, employee contributes $600).
Remember: Health FSAs funded exclusively by employee salary reduction contributions (with annual coverage capped by the amount of the annual salary reduction election) will, by definition, satisfy the Maximum Benefit Condition.
4. In 2014, can an employer still offer a stand-alone Health FSA?
Yes, so long as the stand-alone health FSA qualifies as HIPAA-excepted. For a stand-alone health FSA to be considered to provide only excepted benefits, it must meet one of the following designs:
• Limited scope dental and vision benefits that are not an integral part of a group health plan are excepted benefits.
• If other group health plan coverage not limited to excepted benefits is made available for the year to employees by the employer, and the FSA is structured so that the maximum benefit payable to any participant cannot exceed two times the participant’s salary reduction election for the arrangement for the year (or, if greater, cannot exceed $500 plus the amount of the participant’s salary reduction election).
5. If a health FSA is considered to be a non-excepted benefit, what are the consequences?
A health FSA that does not qualify as an excepted benefit is generally subject to the Act’s market reforms, including the preventive services requirements, unless it is grandfathered. The IRS and DOL had previously ruled that a health FSA is not subject to the annual dollar limit prohibition, irrespective of whether the health FSA provides only excepted benefits. Because a health FSA that is not an excepted benefit is not integrated with a group health plan, it will fail to meet the preventive services requirements, unless it is grandfathered.
For failure to meet the Act’s market reforms, an employer could also be subject to fines and penalties.
Larry Grudzien is an attorney practicing exclusively in the field of employee benefits. He has experience in dealing with qualified plans, health and welfare, fringe benefits and executive compensation areas. He has more than 35 years of experience in employee benefit law and is an adjunct faculty member of John Marshall Law School’s LL.M. program in employee benefits and at the Valparaiso University School of Law, where he teaches a number of courses.
https://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.png00michbusinesshttps://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.pngmichbusiness2013-10-28 17:00:002015-10-08 00:00:00Review of Recent Guidance on the Impact of Health Reform on Cafeteria Plans
By Kristi R. Gauthier, Esq. Clark Hill PLC
Oct. 29, 2013
In order to make health insurance coverage more affordable to individuals and families with lower and moderate incomes, the Patient Protection and Affordable Care Act (PPACA) provides financial assistance, in the form of premium subsidies, for individuals purchasing insurance coverage on the Marketplace (also known as the Exchange). However, even with the Exchanges up and running as of October 1st, many people, including employers, are still struggling to understand who is eligible for a premium subsidy.
Who Is Eligible for the Exchange Premium Subsidies?
Citizens and legal residents of the United States in families with incomes between 100% and 400% of the federal poverty level and who not offered affordable, minimum value coverage through an employer are eligible to receive a premium subsidy to reduce the cost of health coverage on the Exchange.
Who Is Not Eligible for Exchange Premium Subsidies?
The following individuals are not eligible to receive subsidies for Exchange coverage:
Non-citizens or legal residents of the United States.
Individuals in families with household income in excess of 400% of the federal poverty level.
Individuals who are eligible for public coverage, such as Medicaid.
Individuals who are offered affordable and minimum value coverage through an employer.
What is the Amount of the Exchange Premium Subsidy?
The amount of the premium subsidy varies with income level and is structured so that the cost an eligible individual would have to pay for silver level coverage (a “70/30 plan”) does not exceed a specified percentage of the individual’s income, as follows:
Income Level
Premium as a Percent of Income
Up to 133% FPL
2% of income
133-150% FPL
3-4% of income
150-200% FPL
4-6.3% of income
200-250% FPL
6.3 – 8.05% of income
250 – 300% FPL
8.05 – 9.5% of income
300 – 400% FPL
9.5% of income
How Will Individuals Know They Are Eligible for Exchange Premium Subsidies?
When individuals shop for coverage on the Exchange, they will be asked to predict their income for 2014 and based on this information, as well as IRS information for the previous year’s income reporting, individuals will be informed of the applicable premium subsidy amount, if any.
If an individual’s income changes from what was predicted and reported to the Exchange, the individual will be obligated to reconcile the premium amount paid with the amount the individual was actually entitled to receive based on actual income levels. If the individual receives more than he/she was entitled to, he/she will owe it back in the form of additional federal taxes. (Note: There are some caps on the amount a person has to pay back, based on their income.)
How Does Employer Provided Coverage Impact an Individual’s Ability to Obtain a Premium Credit for Exchange Coverage?
If an employer, regardless of size, provides health coverage to its employees that is considered “affordable” and of “minimum value” the employees would not be eligible for any premium subsidies on the Exchange. This does not mean that the employees could not purchase coverage on the Exchange, it only means that they would not be eligible for any premium subsidies.
If an employer offers health coverage to its employees but that coverage is not affordable or of minimum value, such an offer of coverage would not preclude an individual from obtaining a premium subsidy. With that said, beginning in 2015 if the employer is an “Applicable Large Employer” (meaning an employer that averaged 50 or more full-time equivalent employees in the previous calendar year) and a full-time employee is eligible to obtain a premium subsidy, the employer could face potential penalties under PPACA’s employer shared responsibility provisions.
*This article is not intended to give legal advice. It is comprised of general information. Employers facing specific issues should seek the assistance of legal counsel.
Kristi R. Gauthier is a senior attorney in Clark Hill’s Birmingham office and concentrates her practice in Employee Benefits Law. Kristi has represented clients in a wide variety of employee benefits issues involving health and welfare benefits, as well as retirement plans. Kristi is admitted to practice in the State of Michigan, the U.S. District Court for the Eastern District of Michigan, and the U.S. Sixth Circuit Court of Appeals. She also is active in the legal community with memberships in the American Bar Association, the State Bar of Michigan, and the Oakland County Bar Association where she is a member of the Employee Benefits Committee. Kristi also serves as a member of the Clark Hill Diversity and Inclusion Committee. Kristi has lectured on various employee benefits issues, including ERISA compliance, healthcare reform, COBRA, section 125 plans, 403(b) plans and IRS plan correction programs. Kristi is also a co-author of the ABA publication ERISA Survey of Federal Circuits. Kristi was named a “Rising Star” by Michigan Super Lawyers in 2011.
Protect yourself from Random DOL Audits! The
MBPA Provides Legally Compliant Summary Plan Descriptions (SPDs) At No Cost To Our Members!
The Employer Retirement Income Security Act (ERISA) guidelines make it mandatory for all businesses with 2 or more employees to provide employees with a Summary Plan Description (SPD). The MBPA continues to take a leading role in informing and helping our members meet their obligations under ERISA.
The MBPA Welfare Benefit Plan Basic Summary Plan Description and Legal Wrap Plan Document is compliant with all applicable laws, including health care reform to date. This document can be used by groups of all sizes, including large groups and self-funded groups. This document is intended to be a “wrap” plan document and SPD that would work in conjunction with the underlying benefits policies/certificates for insured benefits and with underlying benefit summaries and/or administrative service agreements in the self-insured context. MBPA provides this document as a service to its members who are always encouraged to work with their legal counsel to ensure that the documents are properly completed and tailored to fit the needs of each individual member organization.
NO COST ACA EMPLOYER NOTIFICATION OF THE MARKETPLACE ARE ALSO STILL AVAILABLE AS AN ONGOING SERVICE TO OUR MEMBERS.
If you have questions or are in need of assistance, please contact our Member Services Team at 1-888-277-6464 or 1-586-393-8800.
https://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.png00michbusinesshttps://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.pngmichbusiness2013-10-07 12:23:572015-10-08 00:00:00SPDs at No Cost to Members
Oct. 1, 2013 – More than 200 people gathered Sept. 24 at the MBPA Health Care Reform Conference in Troy to learn more about the operational impact of the ACA on their business and employees, hear from experts and ask questions about various aspects of the law.
The conference opened with a session focusing on the operational effects of the ACA on businesses, featuring remarks by Kristi Gauthier, senior attorney at Clark Hill, and Don McAnelly, CPA and Principal in Charge at Rehmann’s Saginaw office.
A highlight of the conference was the session featuring Todd Stankewicz, a representative from the U.S. Dept. of Health and Human Services; Gerald L. Moore, District Director, U.S. Small Business Administration’s Michigan Office; and Nichelle D. Gray, Tax Specialist and Stakeholder Liaison from the Internal Revenue Service.
Stankewicz provided an overview of the health care Marketplace, which goes into effect Oct. 1, 2013. Noting that the Marketplace is set up to allow for direct comparison between plans, Stankewicz said it should make shopping for health care coverage easier for people. Open enrollment through the Marketplace begins Oct. 1, 2013 and continues through March 31, 2014.
In Michigan, Stankewicz said, there are four navigator organizations to help consumers understand new health insurance options available through the Marketplace and can help them select a health plan. In Michigan, the ACA navigators are: Michigan Consumers for Healthcare, Community Bridges Management, the Arab Community Center for Economic & Social Services, and American Indian Health and Family Services of Southeastern Michigan.
Navigators will help consumers prepare electronic and paper applications to establish eligibility and enroll in coverage through the Marketplace, which will be available at HealthCare.gov and CuidadoDeSalud.gov starting on October 1.
Todd Stankewicz, representative from the U.S. Dept. of Health and Human Services, speaks about the ACA at the Health Care Reform Conference.
Additional assistance is available through Certified Application Counselors (CAC), said Stankewicz. A Certified Application Counselor may be a community health center or other health care provider, hospital, a non-federal governmental or nonprofit social service agency in a state with a Federally-facilitated Marketplace or a State Partnership Marketplace, which assists people applying for coverage through the Marketplace. Both Navigators and CACs go through training before assuming these roles.
He also noted that there is a toll-free call center to answer Marketplace questions 24 hours a day, seven days a week. The number is 1-800-318-2596. People can also connect via Facebook: http://www.Facebook.com/HealthCare.gov or Twitter: @HealthCareGov.
Professionals who want to learn about the Marketplace and helping people apply can visit http://marketplace.cms.gov/.
SBA District Director Moore noted that his agency is hearing from many business owners who do not understand the ACA. To help provide information to small businesses, the SBA has been hosting educational sessions. He encouraged small business owners in the audience to learn whether they are eligible for the ACA tax credits and if they are, to use them. He also said that 4 percent or less of small businesses are affected by the shared responsibility portion of the bill.
Nichelle Gray from the IRS, who participated in the session by phone, also touched on the tax credits and other tax aspects of the ACA.
All three presenters fielded a number of questions from the audience, ranging from employee coverage for businesses with fewer than 50 FTEs, to coverage for the self-employed and how the expansion of Medicaid in Michigan may impact their employees.
The conference wrapped up with a Town Hall style meeting where attendees could ask questions from experts representing Blue Cross Blue Shield of Michigan, Clark Hill, Rehmann, State of Michigan and BASIC. Carol Cain of the Detroit Free Press and CBS 62 moderated the Town Hall.
Sponsors of the conference were: Blue Cross Blue Shield of Michigan, Clark Hill, BASIC, Michigan Small Business Training and Development Center, and 101 Best and Brightest Companies to Work For.
https://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.png00michbusinesshttps://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.pngmichbusiness2013-09-30 17:00:002015-10-08 00:00:00MBPA Health Care Reform Conference Features Experts from HHS, IRS and SBA
October 1, 2013 – To help finance health care reform initiatives created under the Affordable Care Act, the federal government established new taxes and fees that impact health insurers and customers. The Blues are committed to helping customers understand what the taxes and fees are for and what they will cost.
Regardless of the customer’s renewal or plan date, the Blues will begin billing fully insured customers for five ACA taxes and fees starting with Jan. 1, 2014, invoices.
Not all federal and state taxes apply to all segments. Customers will be billed for the applicable taxes and fees.
Your 2014 quotes, renewals and bills will include the amount of federal and state taxes you will need to pay. If you want a detailed breakdown of your taxes and fees, use our taxes and fees estimator tool at bcbsm.com. It now includes the State Insurance Premium Tax and the ACA federal taxes and fees.
To access the tool:
1. Go to bcbsm.com.
2. Go to Help and click on Calculators and Tools.
Under Health care reform, click on Health Insurance Tax Estimator.
Excerpted from BluesMarketplace Customer Edition, August 21, 2013
https://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.png00michbusinesshttps://mb-wp-uploads.s3.us-east-1.amazonaws.com/2024/04/MichBusiness-logo.pngmichbusiness2013-09-30 17:00:002015-10-08 00:00:00News from Blue Cross on ACA Taxes and Fees
By Scott Foster
By Kristi R. Gauthier, Esq.
Oct. 1, 2013
October 1, 2013 