Implementing the Affordable Care Act: Countdown to Employer Requirements

Transcription

1 Implementing the Affordable Care Act: Countdown to Employer Requirements What you need to know about being in compliance American Health Care Association August 6, 2013 The Patient Protection and Affordable Care Act Is the law of the land today Applies to all businesses in the US, including governments Requires almost all individuals to obtain health insurance coverage or pay a penalty Establishes health insurance exchanges (state or federal) Employers with 50+ FTE employees may have to pay a penalty if they don t offer full-time employees affordable, minimum level health insurance after 1/1/2015 Implementation details continue to be outlined through the issuance of new regulations, guidance, and FAQ documents from IRS, HHS, DOL 2 1

2 Variables Effecting Costs for Employers State where business is operated & employee resides State vs. Federal Exchange Medicaid Expansion Employer premium deductibility vs. non-deductible penalty Offer vs. don t offer health insurance today Number of Full-time employees % of FT employees who enroll vs. don t enroll in employer coverage Wages of workers Employer contribution, if any, toward employee premiums : W-2 Disclosure of Health Coverage Cost ACA requires employers to disclose employerprovided health benefits costs on W-2s [IRC Sec. 6051(a)] Includes medical insurance, dental and vision plans(unless separate plans), and self-insured arrangements No reporting for employee salary-reduction FSAs or employer HSA or Archer MSA funding Include family coverage amount, if applicable 2011 implementation was delayed, reporting began for most employers for 2012 expenses 4 2

3 2012: W-2 Disclosure of Health Coverage Cost W-2 reporting of health care costs began for W-2s issued for 2012 benefits (January 2013 issuance). Small Employers fewer than 250 W-2s in 2011 Disclosure is optional for 2012 and until further guidance is issued, at least until January Additional Resources Interim implementation guidance: IRS Notices : updated Notice : W-2 form: 6 Eligibility for Health Insurance Exchange Notice Employers to notify employees upon effective date and/or date of hire: Information about the existence of state/federal exchange, services offered and how to contact Employee may be eligible for assistance to purchase insurance via the Exchange Employee loses eligibility for employer contribution to health benefits if purchases insurance via the Exchange Effective: For current employees, must issue notices prior to October 1, For new hires after 10/1/2013, the notice must be provided within two weeks of hire. Employers who are: Subject to Fair Standards Labor Act Hospitals Institutions who care for the sick, the aged, mentally ill, or disabled who reside on the premises Schools for children with mental or physical disabilities or gifted Preschools, elementary and secondary schools, and institutions of higher education Governments agencies. 3

4 Eligibility for Health Insurance Exchange Notice (cont). Notice of coverage options must be provided to each employee, regardless of plan enrollment status (if applicable) or of part-time/full-time status Department of Labor has model notice language available on its website Employers who offer a health plan: Employers who do not offer a health plan: Additional Health Plan Fees/Taxes Patient-Centered Outcomes Research Institute (PCORI) Fee (2012) Effective for plan years ending on or after 10/1/2012 Requires health insurance and self-insured plans(employer) to pay a per participant fee Fee Year 1: $1/participant Year 2: $2/participant Due by 7/31/ : Inflation adjusted rate 9/30/2019: Phased out IRS indicated it is tax deductible Filed on Form 720 Transitional Reinsurance Fee (2014) Third Party Administrators pay on behalf of the Plan Remit annual contributions to support reinsurance payments to issuers $63 per covered employee and their dependents in 2014 Phases out: $42 in 2015; $26 in 2016 First quarterly payment due 1/15/14 4

5 Health Plan Fees/Taxes Cadillac Plan Tax (2018) 40% excise tax assessed on health insurer or plan administrator offering high-cost health coverage High cost = annual premium > $10,200 single coverage > $27,500 family coverage Tax would be on premiums above the thresholds Goal is to generate revenue to help pay for coverage for the uninsured and to make the most expensive plans less attractive Day Waiting Period: Newly Hired, Full-Time Employees Beginning January 1, 2014, an employer s waiting period for insurance generally cannot exceed 90 days IRS Notice provided guidance on 90-day waiting limitation (Public Health Service Act 2708) Newly Hired, Full-Time Employees. If employee is reasonably expected to be full-time, then must be eligible to enroll within 90 days of start date Not permitted to wait until the 1 st of the month after 90 days May require employers to allow mid-month enrollment or participate well before 90 days have passed 5

6 90-Day Waiting Period & Variable Hour Employees Allows an employer to take a reasonable period of time to determine whether the employee meets plan s eligibility requirements can include a measurement period of up to 12 months can include an administrative period up to 90 days Coverage must be effective no later than 13 months from employee s start date coverage must be effective no later than 13 months from employee s start date if employee s start date is not the first day of a calendar month, will include remaining time until the first day of the next calendar month What does the employer penalty delay mean for individuals and employees? Individual mandate: In 2014, individuals will still need to obtain minimum essential coverage or pay a penalty Health Insurance Exchanges are still scheduled to open for enrollment October 1, 2013 Exchange subsidies still available in 2014: Individuals who earn between % of FPL and do not have access to affordable coverage through an employer may still be eligible for tax credits and/or cost sharing assistance Guarantee issue and no pre-existing condition denials permitted 12 6

7 2014: Individual Mandate Individual mandate to obtain health coverage: Beginning in 2014, most individuals must obtain a minimum-level of health insurance coverage or pay a penalty Minimum essential coverage includes: Medicare, Medicaid, TRICARE Insurance purchased through an Exchange, or the individual market Employer-sponsored coverage that is affordable & provides minimum value Grandfathered plans (group plan in effect on 3/23/2010) Hardship exemption Premium cost for lowest cost plan > 8% of Household Income Penalties for failure to obtain coverage: In 2014: greater of $95 or 1.0% of income In 2015: greater of $325 or 2.0% of income In 2016: greater of $695 or 2.5% of income Penalty is capped at three times the per person amount for a family Assessed penalty for dependents is half the individual rate 13 Health Insurance Exchanges Two Channels: Who can participate? Employers 2014: small employers (state choice: 50 or fewer, or 100 or fewer FTEs) can offer an Exchange plan as their employer health plan 2016: Available to all employers with 100 or fewer FTEs. 2017: states can opt to allow large employers to participate Individuals: Includes self-employed or unemployed individuals (2014) Each state must either establish a health insurance exchange, participate in a federal partnership exchange or a federallyfacilitated exchange for its state s residents. 14 7

8 State Health Insurance Exchange Decisions as of 5/28/13 Source: Kaiser Family Foundation, as accessed June 24, 2013 at: 15 Types of Exchanges State-Based State Partnership Federally-Facilitated State role: All exchange activities such as: web portal development/ operation health plan selection application format. State may request federal government assistance for: Income verification for Exchange subsidies Individual mandate exemptions Risk adjustment requirements Reinsurance program State role: Health plan management Plan selection Licensing Consumer assistance Both Federal role: HHS responsible for all exchange activities, including: application, web portal, plan selection. State role: States may elect to run or seek federal government assistance for: Reinsurance program Medicaid and CHIP eligibility assessment or determination May retain rate setting oversight for health plans offered on the Exchange for their residents. 16 8

9 Exchange Trends Who is participating in the Exchanges? Insurers already active in market are most likely to offer plans in marketplace Typically, more insurers participating in individual vs. SHOP channel Some state SHOPs have only one insurer offering plans and they don t always cover entire state geography Still unknown which plans may offer a national plan via the Federally Facilitated Exchange Plans offered appear to have narrower provider networks Preliminary and Approved Premium Rates State regulators are negotiating for lower rates Great variability in whether Exchange premiums are higher or lower than current 17 Defining small and large employers The definition of large employer varies depending upon the section of the law one is referring to: For Employer Penalties: 50 or more full-time employees plus full-time equivalents. FT employee: avg. 30 or more hours of service per week FT equivalents = Hours worked in a month by all PT employees divided by 120 Eligibility for Premium Tax Credits: 25 or fewer employees earning < an avg. of $50,000 Eligibility for the SHOP: Fewer than 50 OR Fewer than 100 Employer who must auto-enroll: employees 18 9

10 Implications for Small Employers Small Business Health Options Program (SHOP) State-based exchanges must operate both the individual and SHOP exchange. Employers eligible to participate 2014: 50 or fewer full time-equivalent employees (FTEs) 2016: Up to 100 FTEs Self-employed with no employees eligible for individual channel not SHOP Employers participating in SHOP Must offer coverage to all FT employees (e.g. average 30 hours +per week) May be required to meet additional State-specific participation criteria Minimum employee participation requirement (e.g. 75%) 20 10

11 Unique SHOP functions Assist qualified employers and facilitate enrollment of eligible employees into a SHOP plan based upon employer selections Aggregate premiums: Provide participating employers with one monthly bill that accounts for premium payments for all enrolled employees Bill is paid to SHOP rather than each health plan SHOP direct payments to health plan Display employee s premium cost for eligible plans after subtracting the employer contribution Mitigates risk and adverse selection in SHOP exchange (risk adjustment programs and possible minimum employer contribution/employee participation requirements) 21 SHOP: Employer/Employee Choice Models Allows small employers a variety of approaches for selecting the coverage they offer to employees via the SHOP Full employee choice: may choose any plan at any tier level Partial employee choice: employer chooses tier level and employee may choose any plan available at selected tier level Single plan with varying coverage tiers: Employers select specific SHOP plan and employees select their preferred coverage tier (cost sharing levels) Employers select a reference tier level and employee may choose any available plan in that tier or adjacent tiers Full employer choice: employers select SHOP plan at specific coverage level ; employees only choose whether or not to enroll 22 11

12 Tax Credit for Small Employer Health Premiums Eligible small employer: Full Credit Employer contributes >50% of employee premium This will only benefit the smallest employers Upper Limit # of FTEs <10 25 Avg. annual payroll per FTE <$25,000 $50,000 Use Form 8941 to calculate credit: Credit amount included either : 1) as part of the general business credit on your income tax return; or 2) if tax-exempt organization, on line 44f of the Form 990-T (must be filed to claim credit) 23 Tax Credit for Small Employer Health Premiums Tax credit for % of employer-provided health insurance premiums (IRC Sec. 45R) Tax Years Taxable Entity Credit Eligible insurance product to qualify for credit: Exempt 501(c) Credit % 25% % 35% Offset Income tax Payroll tax In tax years: Any health insurance purchased from a licensed insurer (defined benefit) In tax years: Employer must purchase coverage via the Exchange. (defined contribution) 24 12

13 Tax Credit for Small Employer Health Premiums Phase-out for 501(c) Exempt Employer ( ) Avg. Wage/FTE FTEs $25K $30K $40K $50K < 10 25% 20% 10% 0% 15 17% 12% 2% % 3% Small Employer Tax Credit Prior Year Credit Can Still be Claimed: Eligible small employers that forgot to claim the credit this year on their tax return, can still obtain the credit if they file an amended return. Credit can be applied to other years: Small employers who did not owe tax during the year, can carry the credit back or forward to other tax years. Can claim credit + business expense deduction: Small businesses can still claim a business expense deduction for the premiums in excess of the credit (because health insurance premium payments exceed the total credit). Sequestration: As of March 1, 2013, the refundable portion of the credit was reduced by 8.7 percent. This reduction is in effect until Sept. 30, 2013 or intervening Congressional action, at which time the sequestration rate is subject to change

14 The Changing Marketplace Family What Is Washington 40 Year Old Family of Size Income Affordable One Two Three Four $15,000 $ Medicaid Medicaid Medicaid Medicaid $20,000 $ $83.17 $33.33 $33.33 Medicaid $25,000 $ $ $91.88 $41.67 $41.67 $30,000 $ $ $ $ $50.00 $35,000 $ $ $ $ $ $40,000 $ $ $ $ $ $45,000 $ $ $ $ $ $50,000 $ $ $ $ $ $55,000 $ $ $ $ $ $60,000 $ $ $ $ $ You Offer 75% Plan $50.00 $ $ $ Medicaid 94% 85% 73% 70% No Subsidy 27 Strategies for Small Employers Understand your options inside the SHOP Take advantage of employer premium tax credits, when available Evaluate value of employer premium tax credit via Exchange vs. any discounts or premium costs for small group products outside the Exchange. Move to a defined contribution strategy Consider what you can afford to offer vs. what is available to employees in the Exchange 28 14

15 Implications for Large Employers Pay or Play Variable Hour Employees 2015: Potential Large Employer Penalties Law does NOT require employers to offer health insurance Large employers subject to one of two shared responsibility penalties if any FT employee receives Exchange subsidies For employers that own multiple companies, the 50 + employees is determined by control group or affiliated service group For minimum essential coverage, see IRS Notice at: Large employer = 50 or more full-time employee + FTEs FT employee = avg. 30 or more hours of service per week FT equivalents = Hours worked in a month by all PT employees divided by

16 Employer shared responsibility penalties Penalty only assessed if a FT employee receives Exchange subsidies. Employees ineligible for subsidies if employer coverage affordable No Insurance Coverage Penalty Amount = $2000 x each full-time employee (after first 30 employees) Unaffordable Employer Coverage Penalty If employer fails to offer coverage that is: 1. Minimum essential coverage and minimum 60% actuarial value offered to employees and their children under age Affordable = Employee premium cost for single coverage < 9.5% of household income. Amount = $3000 x # of FT employees who receive exchange subsidies Affordable = the employee premium contribution for single coverage is less than 9.5% of their MAGI household income, or one of three employer safe harbor options exist. (e.g., W-2 wages) Maximum penalty = no insurance penalty Inflationary adjustments to penalties begin in 2015 Employer pays no penalty for Medicaid eligible employees : Other Employer Requirements Beginning in 2015, large employers (50 or more FT employees + FTEs) will be required to submit an information return to the IRS, including at least the following: Names of FT employees on the health plan Employer contribution levels to employee coverage Plan waiting period length Whether employer-sponsored plan meets minimum essential coverage requirements Large Employers to auto-enroll: Employers with 200+ FT employees will be required to auto-enroll employees into their employer-sponsored health plan Employees can opt out Won t be effective until U.S. Dept. of Labor issues rules. No sooner than

17 Employer shared responsibility penalties delayed until 2015 What does delay mean for large employers? Do not need to offer full-time employees and their dependent children minimum essential and affordable coverage in 2014 No penalties if coverage offered is unaffordable in 2014 No penalties if coverage offered does not meet minimum essential requirements in 2014 No penalties if employer offers no coverage Do not have to file an information return with IRS in 2014 Further guidance from IRS on information return is expected to be issued summer Where to Start Understand and comply with reporting and fee requirements and due dates Calculate and document full-time employees and equivalents If clearly under 50 FT employees and FTEs, evaluate SHOP defined contribution option vs. existing small group market coverage for 2014 and beyond or free standing defined contribution model separate from SHOP If around 50 FTEs, consider strategies and penalty implications If clearly over 50 FTEs, calculate financial impact including penalties Have at least one employee/consultant responsible for monitoring and understanding what your state and/or the federal government are deciding as implementation nears 34 17

18 Tools for a Changing Marketplace Affordable Care Act Implementation tools AHCA/NCAL Support AHCA/NCAL has formed a team with representation from every department to ensure the membership is prepared. The work of the AHCA/NCAL team is guided and overseen by the State Executives. We provide tools to: Survey and engage your employees Find and follow the experts Act immediately to understand impact 18

19 Resources Our major 2013 work areas based on member guidance include: Developed a comprehensive work plan to define communication on topics of interest through 2013 Research on what would be needed for Medicaid Rate Add-Ons to help cover new or expanded employee health care coverage A user-friendly website which includes ACA implementation timelines, issue briefs, a webinar library. NEW Issue brief available on Medicaid Churn. Webinar series on various aspects of the ACA Development of an online calculator to allow members to estimate a penalty figure should they choose not to offer coverage An alert series which provides succinct and timely information on ACA implementation updates Frequently Asked Questions online and a monthly just the facts audio files with experts answering member submitted questions ACA dedicated address, insurancecoverage@ahca.org, which members may use to questions to Association staff Use Our ACA Tools Visit the new website at o To date, AHCA has provided a broad array of Affordable Care Act information on our website. All the information is accessible from our main website, with a member username and password. o Recently added: Nancy-Taylor---March-Employer-Notice-and-Reporting-Requirements.aspx o px o Readiness Checklist for Employer Coverage updated regularly based on new guidance. o Comprehensive Timeline o New Webinar Information o ACA Session at Convention in October and Readiness Booth AHCA/NCAL Insurance Solutions Program. Through Compass Total Benefits, insurance carrier partners will offer AHCA members traditional benefit programs, as well as defined contribution plans. Visit more information. Send questions & sign up for alerts at insurancecoverage@ahca.org 19

20 AHCA Checklist Compliance Issue Compliance Standard Steps to Determining Compliance Deadline for Completion Status Employ at least 50 full-time No fixed deadline; complete equivalent employees in as soon as possible. controlled group of companies. Is my company potentially subject to the penalty for failure to provide coverage (i.e., Employer Shared Responsibility Penalty)? How do I determine which employees may need to be offered health plan coverage? What if employees do not work a consistent schedule? Must offer coverage to full-time employees (and their dependents). Determine full-time status or otherwise based on hours worked during look-back or measurement period. 1. Identify controlled group of companies. 2. Count total number of full-time employees in prior year (i.e., those who work 130 hours or more per month). 3. Count total number of non-full-time employees in prior year (i.e., those who work fewer than 130 hours per month). 4. Count hours worked by non-full-time employees in prior year to maximum of 120 hours per month per employee. 5. Divide total hours worked by non-full-time employees by Add quotient derived in Step 5 to sum counted in Step If number derived in Step 6 is at least equal to 50, controlled group of companies is potentially subject to the Employer Shared Responsibility Penalty. 1. Identify employees for whom there is a reasonable expectation that they will work more or less than 130 hours/month. No fixed deadline; complete as soon as possible to be 2. Deem employees at 130 hours/month and over as full-time employees and employees at less than 130 hours/month as not fulltime employees. prepared to offer coverage to full-time employees at start of plan year beginning 3. Prepare to maintain rigorous records of hours actually worked to support classification of workers in the event of an audit. on or after 1/1/ Prepare to communicate status with employees and ensure compliance with applicable employment law standards. 5. If not already offering, dependent coverage must be offered starting in 2015 (special rules apply). 1. Look-back or measurement period may be as short as three and as long as 12 months. 2. Evaluate work patterns to determine appropriate look-back or measurement period. 3. Count hours worked during each month in look-back or measurement period. 4. Determine average monthly hours during look-back or measurement period. 5. If average hours equal or exceed 130/month, classify as full-time and prepare to offer coverage during stability period (see below). No fixed deadline; complete as soon as possible to be prepared to offer coverage to full-time employees at start of plan year beginning on or after 1/1/14. What steps must I take with respect to employees that are deemed or determined to be full-time? What kind of coverage do I have to provide? How much can I charge my employees for coverage? Employer must offer coverage, effective within 90 days of employee becoming eligible. Coverage must provide minimum value. AHCA Checklist 1. For all full-time employees (and their dependents), employer must offer coverage. No fixed deadline; complete as soon as possible to be 2. Prepare to keep records of offers of coverage made, including employee acknowledgement. prepared to offer coverage at start of plan year 3. Once employee (and their dependents) determined eligible, employer beginning on or after can apply a waiting period or administrative period of no more than 1/1/ days (not equal to 3 calendar months). 4. Coverage must be offered for a stability period equal to the greater of six months or the length of any look-back or measurement period. 5. Starting after 2014, employers with more than 200 full-time employees may be subject to automatic enrollment requirements. 1. Minimum value means that a plan covers 60% of the costs of the benefits that are offered. 2. Use one of four options to determine if the plan provides minimum value: a. HHS Minimum Value Calculator; b. Eyeball whether plan aligns with one of HHS/IRS provided safe harbor designs; c. Obtain actuarial certification of any plan design that is not accommodated by the MV calculator; or d. If purchasing small group coverage, any plan purchased through the Exchange from any metal tier will qualify. Coverage must be affordable. 1. Affordable coverage means that the premium charged for coverage for individual employee not including spouse or dependent coverage does not exceed 9.5% of the employee s household income. 2. Employers will be considered compliant if plan(s) offered are affordable based on individual s income derived from the employer. 3. Use one of three safe harbors to measure affordability of coverage: a. 9.5% of W-2 income; b. 9.5% of monthly rate of pay; c. 9.5% of the Federal Poverty Level. No fixed deadline; complete as soon as possible to be prepared to offer coverage at start of plan year beginning on or after 1/1/14. No fixed deadline; complete as soon as possible to be prepared to offer coverage at start of plan year beginning on or after 1/1/14. What information must I provide Employer must provide 1. Uniform Summary of Benefits and Coverage (SBC) is a template 1. During open enrollment 40 20

21 AHCA Checklist What information must I provide to my employees? Will I be subject to any other reporting requirements? Employer must provide employees with: Uniform Summary of Benefits and Coverage; Exchange Notice; and Employer Coverage Tool Information. 1. Uniform Summary of Benefits and Coverage (SBC) is a template employers must use to provide information about health care coverage in simple, accessible terms. 2. The Exchange Notice is a written notice informing employees of the Exchange, how they can get assistance, and if the employer plan does not provide minimum value or affordability, the availability of tax subsidies in the Exchange. 3. The Employer Coverage Tool Information is part of an employee s application for coverage through the Exchange that an employer must complete with information about available employer-sponsored coverage options. W-2 Reporting Requirements. 1. Employers must report cost of employer-sponsored health coverage on their W-2s, including portions paid by both the employer and the employee. 2. Other reporting requirements to the IRS may be effective in years after During open enrollment or on first day of plan year for newly eligible or special enrollees. 2. October 1, 2013 and within 2 weeks of start date for new hires thereafter. 3. As requested by employees; may include with Exchange Notice for all employees not eligible for employer coverage. At time of filing the W Employer Health Insurance & Penalty (HIP) Costs Impact of Employer Health Insurance Reforms HEALTH REFORM SUBSIDIES IMPACT ON HEALTH COSTS Full-Time Employees 80 (37 Insured / 43 Waived) Sample Today's 2015 Offer 2015 Drop/ Total Staffed 92 (0 PT Insured/12 PT No ESI) ($000s) Cost Coverage Don't Offer 2015 PPACA FTEs 89 Baseline Premium Cost $ 232 $ 232 $ 232 HEALTH REFORM KEY DRIVERS Premium Increase (9.0% / Yr) Single Coverage Employer Premium Cost Pre-Reform Projected Premium Cost Average Single Employer Cost $ 4,534 Tax Adjusted Premium Costs Current Employer Contribution % 60% PLUS: Additional Reform Impact Medicaid Eligible Employees Previously Waived FT Employees Total FT Medicaid Enrollees 2 Penalty: Subsidy Eligibles & ESI Employer Estimated Cost Savings $ 9 ($000s) Health Reform Increased Cost Employer Unaffordable Coverage Penalty Subsidy Eligible Full-Time Employees 41 LESS: Previous Premium Liabilities Subsidy ($3,000) $ 3 Medicaid Employee ESI - (9) - Estimated Subsidy Penalty $ 123 ($000s) Subsidy Eligible FT Employees ESI - (224) - % Total Full-Time Employees 51.3% Health Reform Decreased Cost - (233) - Employer No ESI Insurance Penalty No Minimal Essential Coverage Total Full-Time Employees 80 Less: 2015 Inflation Adjusted HC Cost - - (276) Less: 30 Employees (30) Plus: Subsidy Eligible Penalty Adjusted Full-Time Employees 50 Health Reform No ESI Cost - - (176) No Insurance Penalty ($2,000) $ 2 Post Reform HC Costs $ 232 $ Estimated Subsidy Penalty $ 100 ($000s) HC Cost Change to 2015 Projected $ 62 $ (176) 2015 Pre Reform Projected HC Costs $ 276 ($000s) % HC Cost Change to 2015 Projected 22% -64% Estimated Net Savings $ 176 ($000s) Tax Adjusted HC Costs $ 151 $

22 Employee Exchange Subsidy Eligibility Factors 0.0% - 6.5% 6.5% - 8.0% 8.0% - 9.5% 9.5% % 11.0% %+ Health Insurance Affordability 11.3% 20.0% 15.0% 13.8% 30.0% 10.0% Qualified For Exchange Subsidies (Including Medicaid) Exchange Subsidy Eligibility = ESI Affordability + Income between % FPL 400%+ Income as a % Above FPL 10% 8 250% - 400% 138% - 250% <138% 39% EE's Income 46% 38 Qualified MA Eligible= 2 2% In 2015, employer pays penalty when a FT employee is eligible for Exchange Subsidy Coverage Breakdown Post Reform ESI FT Employee Mix 37, 46% 2, 3% Medicaid Eligible Subsidy Eligible ESI Coverage 41, 51% We estimate 51% of your full-time employees will be eligible for Exchange subsidies, 3% employees eligible for Medicaid, and the remaining 46% enrolled in ESI

23 Average Premium Cost Per Employee Perspective <= 138% FPL 139% -250% FPL 6,405 6,981 2,589 2,822 2,000 3,816 4, ,000 - Today 2015 Pre Reform ESI 2015 Post Reform Post Reform ESI 2015 No ESI Employer Share Employee Share Gov't Subsidy 4,037 4,400 5,947 6,482 1,450 1,450 3,000 2,000 2/3% Total (2/5% FT Employees + 0/0% Waived Converted) 38/48% Total (15/41% FT Employees + 23/53% Waived Converted) 251%-400% FPL 9,984 10,882 12,286 7,836 11,286 7,836 Today 2015 Pre Reform ESI2015 Post Reform ESI2015 Post Reform No ESI Employer Share Employee Share Gov't Subsidy 400+% FPL 10,534 11,482 9,883 11,601 4,259 4, ,840 6,303 6,275 6,840 5,577 3,298 2,000 Today 2015 Pre Reform ESI 2015 Post Reform ESI 2015 Post Reform No ESI 16,251 12,794 13,945 14,251 5,172 5,637 5,761 14,251 7,622 8,308 8,490 2,000 Today Pre Reform Post Reform Post Reform 2015 ESI 2015 ESI 2015 No ESI Employer Share Employee Share Gov't Subsidy Employer Share Employee Share Gov't Subsidy 32/40% Total (13/35% FT Employees + 19/44% Waived Converted) 8/10% Total (7/19% FT Employees + 1/2% Waived Converted) 45 Health Insurance and Penalty (HIP) Calculator Connect.com/HIP 23

24 Questions? Nicole O. Fallon Health Care Consultant CliftonLarsonAllen LLP For more information on health reform: /healthreform Thank you! CLAConnect.com twitter.com/ CLA_CPAs facebook.com/ cliftonlarsonallen linkedin.com/company/ cliftonlarsonallen 47 24