Tag: PPACA

Question: Does the play or pay penalty apply to a large group prior to their renewal date in 2014 if the plan is on a fiscal year (7/1/14)? Answer: For large employers, the DOL has issued special rules for plans not on a calendar year.  In January of 2013, the Department of Labor announced “transition…

Ask the Experts: The following question recently came from one of our clients requesting our assistance to better understand and manage this issue.  Question:  When PPACA’s guidelines on excessive waiting period limits go into effect for plan years on or after January 1, 2014, does this mean that groups can no longer have a waiting period…

Question: We have a client that has over 100 employees at the headquarters office.  They also have a smaller company in another state where they own 90% of the company.  The companies are operated separately and have separate medical plans on different plan years.  Do they have to have the same benefits for both companies under…

Question: Will an employer group of less than 50 FTE employees that chooses to offer a PPACA-qualified health plan to their employees have to comply with requirement that employees working 30+ hours must be offered coverage? Answer: The short answer is NO.  The Affordable Care Act (federal health care reform) does not impose penalties on employers based…

Question:  Can you please explain the new health care reform “fee” on HRA plans to fund medical research and how it works, what it costs and how it will be paid? Answer: The “fee” you are referring to related to health care reform is the one placed on health plan carriers (for fully insured plans) and…

Question: Under the PPACA rules, are employers required to offer health care coverage to spouses? Answer:  No.  The coverage “offer” requirement under the PPACA’s play-or-pay rules defines “dependents” as the employee’s children under age 26.  Spouses are not included as “dependents” for purposes of the Act’s coverage offer requirement. Current regulatory guidance applies at least through 2014.  

Question: We have had clients tell us that they were asked if they had proof of health insurance when they had their taxes done. Does that make sense when the health insurance mandate under PPACA doesn’t go into effect until 2014? Answer: You are right, as it relates to the health insurance mandates that begin in…

Question: Do you have an outline of the different coverage requirements for silver, bronze and gold as far as health care reform requirements? Answer: In summary fashion, PPACA defines specific levels of coverage to be offered by the state exchanges. They are: BRONZE LEVEL– A plan at the bronze level shall provide a level of coverage that…

Question: When employers participate in a multiemployer plan subject to a collective bargaining union agreement, and the union does not comply with health care reform requirements (minimum value insurance, annual notices, etc) what is the employer’s available recourse? Answer: In general, collectively bargained healthcare plans have to comply with the requirements of the PPACA at the same…

Question: When PPACA’s guidelines on excessive waiting period limits go into effect for plan years on or after Jan 1, 2014, does this mean that small groups can no longer have a waiting period that is “the first of the month following 90 days”? Answer: The current thinking (absent explicit guidance from the IRS/DOL on the 90-day…