Health Care Reform: Preparing for 2015 and Beyond

Transcription

1 Health Care Reform: Preparing for 2015 and Beyond This is only a brief summary that reflects our current understanding of select provisions of the law, often in the absence of regulations. All of the interpretations contained herein are subject to change as the appropriate agencies publish additional guidance.

2 Agenda ACA Full Time Tracking and Reporting ACA Cost Implications Future Compliance Requirements Employer Alternatives

3 ACA Full Time Tracking and Reporting

4 Tracking Hours Full time is 30+ hours/week or 130+ hours/month Counting hours Work and non work time for which pay is due Service records or use of equivalency Include common law employees Volunteer hours

5 Measurement Period Approach 90 Days Year 1: Measurement Period Admin Period Stability Period 3 12 Months 6 12 Months* Year 2: Measurement Period Admin Period Stability Period * Must be at least as long as Measurement Period

6 Special rules for educational institutions Apply if 4+ week break in service Two methods for determining full time employees Use measurement period excluding break Treat employee as credited with hours for the employment break Includes anti abuse rule

7 Final notes on counting hours worked Changes in employment Breaks in service 13 weeks (26 weeks for Educataional Institutions) Rule of parity Special unpaid leave

8 Employer Reporting Requirements Two components: Section 6055: Minimum Essential Coverage Reporting Section 6056: Large Employer reporting Employers subject to both may combine the reporting

9 Due Dates First reporting will be for calendar year 2015 Regardless of plan year Reporting Deadlines Due to covered individuals by January 31 for the prior year Due to IRS by February 28 or March 31 (if filed electronically) for the prior year Reporting for calendar year 2014 is optional

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16 ACA Cost Implications

17 ACA Added Costs Kaiser Family Foundation. (2015). Health Insurance Fee $8,600 $8,500 $8,400 $8,300 $8,200 $8,100 $8,000 $7,900 $7,800 $7,700 Cost per Employee 7% TRF PCORI ACA Added Benefits Claims and Administrative Expense ($8,000)

18 High Cost Plan Excise Tax

19 Future Compliance Requirements

20 Anticipated Compliance Requirements Non Discrimination Testing Automatic Enrollment Transparency Disclosures Quality of Care Reporting

21 Employer Alternatives

22 Choice Spectrum

23 Before you Decide No one size fits all solution Can offer more than one Two part strategy Transition period

24 Strategies to Consider Self Funding / Pooling Private exchange Health Savings Accounts Health Reimbursement Arrangements Wellness Programs

25 Self-Funding vs. Fully-Insured $10,000 $9,000 $8,000 $7,000 $6,000 $5,000 $4,000 $3,000 $2,000 $1,000 $- Insured $1,200 difference per employee per year Health Insurance Fee Stop Loss Insurance Mandated Benefits Profit Margin Risk Charge State Insurance Premium Claims / Premium Self-Funded

26 Pooling Community rating / small group market Self funded pooling arrangements

27 Private Exchange

28 Account Based Plans Health Savings Accounts (HSAs) Healthcare Reimbursement Arrangements (HRAs) Health Flexible Spending Accounts (FSAs)

29 Account Based Plan Comparison

30 Wellness Programs Many employers are hoping to use wellness programs to help control medical costs Wellness programs must comply with a variety of federal laws Employers may provide incentives for participation and/or reaching health goals Employers have been challenged to prove ROI, but wellness remains an important component of many health plan programs

31 Design Implementation Strategy Benefit design and eligibility Cost management Administrative obligations Impact on employees and workforce structure Employee communication Resource availability

32 Thank you! Ed Pudlowski This is only a brief summary that reflects our current understanding of select provisions of the law, often in the absence of regulations. All of the interpretations contained herein are subject to change as the appropriate agencies publish additional guidance.