Affordable Care Act Toolkit

Transcription

1 Affordable Care Act Toolkit for Businesses with 50 or more employees Choose coverage that fits. Form No (07-14)

2 The Affordable Care Act Blue Cross of Idaho prepared this toolkit to help you define where your business fits in the ACA and understand how the law will impact the coverage you offer your employees. The information in this toolkit is a general overview of the rules, regulations and consequences of the ACA. It may not address every aspect of the ACA that affects employers and their insurance and is not intended to be legal or tax advice. What does it mean for you? The Affordable Care Act (ACA) is the final version of healthcare reform legislation passed by Congress and signed into law in Some of these regulations took effect immediately, while others were rolled out over the last few years. The individual mandate took effect on January 1, 2014, and we expect regulations that impact employers to take effect over the next few years. The ACA requires employers with 50 or more full-time employees to offer minimum essential coverage at an IMPACTS OF THE AffordableŁ Care Act affordable price or pay an IRS tax penalty. The deadline for this rule was delayed a year, until 2015, to allow large businesses extra time to meet the requirements of the law. Blue Cross of Idaho will continue to implement ACA changes and provide you with information about the new regulations and their impact on your health insurance. At its core, the federal government is trying to do three primary things through the ACA: Ensure more people have access to and get health insurance coverage Set coverage standards for Ł health insurance benefits Lower premium and out-of-pocket costs throughł subsidies 2 Affordable Care Act Toolkit from BLUE CROSS OF IDAHO Large roups

3 large roups The ACA and Your Business Employers face the difficult task of determining whether or not it makes better financial sense to offer group health insurance to employees or leave it to employees to purchase their own individual coverage from the online public Health Insurance Exchange. Determining your group size You will need to determine the number of your full-time equivalent employees to better understand how the ACA will impact your business. The ACA affects businesses with 50 or more full-time employees (large groups) differently than it affects those with less than 50 full-time employees (small groups). Full-time and part-time employees will factor into your calculation. 1. Calculate the number of employees who worked more than 30 hours a week for each calendar month in the previous year. 2. Calculate the number of hours your part-time employees worked each month (any employees who exceed 120 hours per month are not considered part-time and should be added to the full-time employee total instead). Divide the total number of part-time hours by 120. This number turns part-time hours into equivalent full-time positions. 3. Add total full-time employees to total full-time equivalents. 4. divide the total by 12 and round down. Total Employees Total Equivalent Employees If you re interested in receiving a Blue Cross of Idaho analysis to assess ACA s impact on your business and employees, contact your insurance broker or local Blue Cross of Idaho district office at Choose coverage that fits bcidaho.com 3

4 randfathered Plans The ACA considers grandfathered plans to meet minimum essential coverage requirements. Tools you can use With your specific employee and business information, we can create a strategic impact report to help you see how the ACA affects your employees and your bottom line now and in the future. This report offers: Premium and cost-sharing estimates for employer-based plans vs. individual plans Estimates of ACA eligibility and affordability for employees Estimates on employee compensation needed to replace the value of the health plan Pre and post-tax implications of terminating current coverage Projected risk of a 40 percent excise tax if you offer what is considered a Cadillac plan The reports we generate provide employers with essential analyses needed to assess potential ACA impacts, such as employee subsidy eligibility for exchange or Medicaid coverage. The report can also provide a preliminary analysis of the financial risk of choosing to become a selffunded program. Deciding to pay or play Since the law was enacted in 2010, we have continually adapted our plans to meet ACA requirements and we will continue to assist you with applicable ACA notification and reporting requirements. Large employers face many decisions regarding health insurance benefit plans and Blue Cross of Idaho is here to help your company navigate those decisions. Are you grandfathered? If your plan was effective prior to March 23, 2010, it may be grandfathered under the ACA. If you have a grandfathered plan, you can continue offering your current coverage and avoiding some of the impacts of the ACA. However, changes you make to your existing health plan can affect its grandfathered status. In general, if you decrease coverage and/ or increase your employees cost-sharing responsibilities, your plan may lose its grandfathered status. For questions about grandfathered coverage, call your account manager, one of our state wide offices at or your health insurance agent. Penalties for Noncompliance large employers must offer minimum essential coverage (MEC) to full-time employees and their dependent children or face a penalty penalties for failing to offer MEC will take effect January 1, $2,000 X (FTE 80)* Employers that fail to offer MEC to full-time staff and dependents and at least one employee receives a tax credit or cost-sharing reduction will pay The lesser of either $3,000 for each FTE receiving assistance or $2,000 X (FTE 30) Employers who offer coverage to full-time staff and dependents, but an employee receives a tax credit or cost-sharing reduction because the coverage is either not affordable or does not provide minimum value will pay *This is 2015 calculation only. For 2016, formula is $2,000 X (FTE 30) 4 Affordable Care Act Toolkit from BLUE CROSS OF IDAHO Large roups

5 large roups Employer responsibilities As we mentioned on page 1, the ACA requires that employers with 50 or more full-time employees offer minimum essential coverage starting in Here s what that means for your business. Note: Some employers offering insurance on a fiscal plan year can wait until their plan renewal date to make changes that comply with the employer shared responsibility provisions. Consult your account manager or the IRS for more information. Provide minimum value coverage To meet this requirement, your health plan must pay for at least 60 percent of covered healthcare expenses. We will work with our existing groups to ensure their group health insurance plans meet the ACA requirements. The adoption of a unique HPID is designed to eliminate the need for multiple identifers and to streamline HIPAA transactions. Identifers may also be used for any lawful purpose to idenfity a health plan or other entity. Employer Shared Responsibility provisions: irs.gov/uac/newsroom/ Questions-and-Answers-on- Employer-Shared-Responsibility- Provisions-Under-the-Affordable- Care-Act randfathered health insurance plans: healthcare.gov/law/features/ rights/grandfathered-plans W-2 Reporting: irs.gov/uac/form-w-2-reporting- of-employer-sponsored-health- Coverage Offer affordable coverage The cost of insurance to employees on both grandfathered and nongrandfathered plans must not exceed 9.5 percent of the employee s annual salary. Obtain a Health Plan Identifer HHS adopted a standard for a unique Health Plan Identifer (HPID) and an other entity identifer (OEID). Choose coverage that fits bcidaho.com 5

6 Self-funded plans with greater than $5 million in annual receipts need to obtain an HPID by November Blue Cross of Idaho is not allowed to apply for an HPID on your behalf. If you re a fully-insured group, then you are not required to obtain an HPID. There are four steps to obtain an HPID. Register your business or organization in Health Insurance Oversight System (HIOS) at portal.cms.gov. Access HIPS user role management. Access Health Plan and Other Entity Enumeration System (HPOES) and select Application Type. Complete and submit your application. Once your application is submitted, an authorization official will review it for accuracy and completeness. Once your application is accepted, CMS will assign you a HPID or OEID number. If you need more information about HPID, or if you d like to watch a step-by-step video, please visit cms.gov Regulations- and-uidance/hipaa-administrative- Simplification/Affordable-Care-Act/ Health-Plan-Identifier.html. Timelines for HPID Compliance Employer To Do List 2015 You need to offer coverage to 70% of full-time employees. Entity Type Health Plans, excluding Small Health Plans Compliance Date for Obtaining HPID November 5, 2014 Full Implementation Date for Using HPID in Standard Transactions November 7, You need to offer coverage to 95% of full-time employees. Small Health Plans* November 5, 2015 November 7, 2016 Now is a great time to start calculating your full-time equivalent employees. We re here to help you learn how to count hours, especially for your part-time and seasonal staff. Covered Healthcare Providers Healthcare Clearinghouses N/A N/A November 7, 2016 November 7, 2016 * Small Health Plan means a health plan with annual receipts of $5 million or less (45 CFR ). 6 Affordable Care Act Toolkit from BLUE CROSS OF IDAHO Large roups

7 large roups Additional Regulations that May Impact You Changes to group size measurements Over the next few years, group size determinations are changing: 2015: roups of 200 or more full-time employees must automatically enroll new employees. This requirement was slated for 2014, but delayed until : roups between 51 and 100 full-time employees will be categorized as small groups instead of medium groups. 2017: roups of 100 or more full-time employees may purchase coverage on the exchange. New health coverage includes all the essential health benefits. Employee waiting period Probationary periods for new employees cannot exceed 90 calendar days. This means if you hire a new employee on June 1, his/her health insurance must begin no later than August 30. However, you can include an orientation period of 30 days to meet your enrollment timeline. Social Security Numbers Starting in 2015, Blue Cross of Idaho and self-funded groups will need to collect and store Social Security numbers. SSNs will be collected at the time of enrollment. Exchange notice Employers should provide employees with information about their health insurance, the Health Insurance Exchange, and possible financial assistance with the cost of insurance. Employees should receive notice within 14 days of beginning work. Blue Cross of Idaho provided group administrators with a template of this notice. Please contact us if you want a copy. Choose coverage that fits bcidaho.com 7

8 IRS reports Forms 1094-C (a transmittal) and 1095-C (an employee statement) for 2015 are due to the IRS by February 28, You must submit a completed Form 1095-C for each full-time employee that includes the following: Enrollee name Enrollee taxpayer ID number or SSN Months the enrollee had coverage for at least one day Name, address and employer ID number Insurer or self-insured contact person and contact number You are required to provide enrollees with a copy of their IRS Form 1095-C (employee statement) no later than January 31 of each year. W-2 reporting requirement Employers with 250 or more employees must report the cost of health insurance coverage on employees W-2 forms. This is intended to provide employees with useful information about the cost of their health insurance coverage. You can find more information about this requirement at: irs.gov/uac/form-w-2-reporting-of- Employer-Sponsored-Health-Coverage. 8 Affordable Care Act Toolkit from BLUE CROSS OF IDAHO Large roups

9 large roups The effects on Your company s coverage and services The following is a summary of Blue Cross of Idaho s coverage and plan changes resulting from the ACA. The information below is a general overview of the ACA regulations and how Blue Cross of Idaho has responded. New and non-grandfathered groups randfathered groups Dependent age We extended coverage for dependent adult children up to age 26, regardless of marital status, income, financial status, educational status or place of residence. Pre-existing waiting periods Expanded January 1, 2014 In 2014, we stopped requiring waiting periods for pre-existing conditions for all members regardless of age. Preventive health services We cover preventive care services at 100 percent, not subject to deductible or coinsurance, when provided by an in-network provider. We also expanded covered preventive services to include additional women s health services. Preventive health services We cover preventive care services at 100 percent, not subject to deductible or coinsurance, when provided by an in-network provider. Annual maximum limit on essential health benefits We removed annual dollar maximums from essential health benefits, including prescription drug services. Lifetime benefit limits Expanded January 1, 2012 We removed all lifetime dollar maximum limits. Choose coverage that fits bcidaho.com 9

10 New and non-grandfathered groups randfathered groups Summary of benefits & coverage (SBCs) Blue Cross of Idaho provides individual members, employer groups and potential members access to a uniform overview of their health insurance coverage. These materials contain a short, easy-to-understand summary of benefits and coverage (SBC) and a list of definitions (called the uniform glossary) that explains terms commonly used in health insurance coverage such as deductible and copayment. Out-of-pocket maximums Effective January 1, 2014 for new groups or at plan renewal The ACA sets a maximum amount your employees have to pay out of their own pockets for services. Effective January 1, 2014, or when your plan renews, this limit is $6,350 for individuals and $12,700 for families. This maximum amount includes all deductibles, coinsurance and copayments for medical services. This limit will vary each year based on federal guidelines. CMS allows two separate out-of-pocket maximums (as might happen if your plan has a separate pharmacy out-of-pocket maximum, for example), as long as the sum total of the two doesn t exceed the maximum. Wellness program incentives Effective January 1, 2014 for new groups or at plan renewal The ACA allows employers who offer wellness programs to increase the incentive for participation to up to 30 percent of the premium contribution. Patient Protections It s important to us that you receive timely information about your health insurance and understand your rights as a Blue Cross of Idaho member. That s why Blue Cross of Idaho will: Respond to urgent care requests for prior authorization within 72 hours of receipt. Provide members with a description of the diagnosis and treatment codes and their corresponding meanings on request. Provide unique, identifiable denial codes/reasons on all adverse benefit determinations and add a general definition of investigational and medical necessity to the explanation of benefits. Provide an external review process. Provide translation of some forms into Spanish, Tagalog, Chinese and Navajo Indian (Dine) on request. 10 Affordable Care Act Toolkit from BLUE CROSS OF IDAHO Large roups

11 large roups Questions and answers What is healthcare reform? The Affordable Care Act (ACA) was passed by Congress and signed into law in Some regulations and laws are already in place and may have impacted your insurance coverage. The primary regulations were effective January 1, I heard that the government delayed some parts of the ACA for a year. What was delayed and what does that mean for my business? The ACA requires employers with 50 or more full-time employees to offer qualified health insurance that provides adequate coverage at an affordable price or pay an IRS tax penalty. This rule was supposed to take effect in However, the federal government delayed the IRS reporting mandate for employers until 2015, giving large businesses extra time to meet the requirements of the new healthcare law. The delay in the employer reporting mandate did not delay the individual mandate, which required all legal US residents to have health insurance by January 1, Can I continue offering my current insurance plan to my employees? If your current health plan was effective prior to March 23, 2010, your plan may be grandfathered, allowing you to continue offering your current coverage. See the grandfathered section on page 4 of this toolkit for more information. How will my coverage change? Depending on the plan you currently have, it may change quite a bit, or very little. Large employers do not have to provide coverage for services outlined as essential health benefits (shown below). However, if your plan provides coverage for these services, the coverage must not contain dollar limits. Ambulatory patient services Emergency services Hospitalization Maternity and newborn care Mental health and substance abuse disorder services, including behavioral health treatment Prescription drugs Rehabilitative and habilitative services and devices Laboratory services Preventive and wellness services and chronic disease management Pediatric services, including oral and vision care Will it cost me more to offer insurance to my employees? The impact of the ACA on your rates will depend largely on the changes you have to make to your existing insurance coverage. Depending on your benefit plan, the ACA may not have much effect on your rates; if you make significant changes to your current plan to comply with the ACA, it may increase your costs. Can I provide a health reimbursement account (HRA) to help my employees pay for individual policies? No. An employer-sponsored HRA cannot be integrated with individual market coverage or with an employer plan that provides coverage through individual policies. Does the ACA put a limit on enrollment waiting periods? As of 2014, the waiting period for health insurance enrollment can t be longer than 90 days. You may include a bona fide orientation period no greater than 30 days in order to meet enrollment timeline needs. Will I be able to buy health insurance from Blue Cross of Idaho? Yes. While individuals, families and small employers may be able to purchase insurance through an online marketplace, companies with the equivalent of 50 or more full-time employees will continue to buy through private carriers such as Blue Cross of Idaho. When do the employer shared responsibility provisions go into effect? Effective January 1, 2015, or at their 2015 renewal date, large employer groups will have to meet the employer shared responsibility provisions. What if I do not offer qualifying insurance to my employees? Starting in 2015, employers with 50 or more full-time employees (or the equivalent of 50 or more full-time employees) must offer affordable health insurance to full-time employees, and the employees dependents under age 26 or pay a tax penalty. You can find more information about these requirements in this toolkit. If I offer qualifying insurance to my employees, can they choose not to take it and qualify for subsidized insurance through the new marketplace? No. Employees and their dependents with access to a an employer-sponsored, qualified health plan are not eligible for subsidies through the marketplace. Choose coverage that fits bcidaho.com 11

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