Perhaps one of the most important elements of the Affordable Care Act (ACA) — the Health Insurance Exchange/Marketplace — will become available to individuals starting on January 1, 2014. The Department of Labor (DOL) requires employers to issue Marketplace Notices to existing employees by October 1, 2013. New employees hired on or after October 1, 2013, must be provided with a copy of the Marketplace Notice within 14 days of the date of hire.
All employers, including those that do not sponsor a group health plan, must provide a form of the marketplace notice to ALL of their employees – including those who are not eligible for employer-sponsored group health plan coverage.
Below are some answers to some of the frequently asked questions we’ve received regarding the Marketplace Notice.
Who do we send the Marketplace Notice to?

• All employees must receive the Marketplace Notice, regardless of whether they are eligible to participate in the health plan (i.e., part-time employees) and regardless of whether they are enrolled in the plan.
• Separate Marketplace Notices are not required to be sent to spouses or dependent children.
• Marketplace Notices are not required to be sent to former employees, regardless of whether they are still covered by or eligible for coverage under the plan (i.e., COBRA coverage).

How do we deliver the Marketplace Notice?

• The Marketplace Notice may sent by first-class mail.
• Marketplace Notices may be delivered by e-mail to those employees who access e-mail as an integral part of their duties.
• Guidance does not state that the Marketplace Notice must be included in a new hire package but we advise that this is an acceptable method of delivery for new hires.

DOL has posted a sample notice, which serves as a useful example of what employers will be expected to share with their employees. DOL also has released a form for employers who do not offer coverage.
Employers can begin using these forms, or create their own modified version, as long as the notice meets the DOL’snotification requirements.
If you have questions regarding these notifications or require assistance in issuing compliant notifications to your employees, call us at 1.800.250.2741 or email solutions@gsanational.com.

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The Internal Revenue Service (IRS) has issued final rules on Tuesday for the individual mandate provision of the Patient Protection and Affordable Care Act (PPACA).
The requirement, a centerpiece of the Affordable Care Act, requires most individuals to have minimum essential coverage in 2014 or pay a penalty. If individuals choose not to carry insurance, they are subject to a penalty, starting at $95 per person per year or 1 percent of income in 2014, whichever is greater, and eventually reaching $695 per person or 2.5 percent of income by 2016.
The first penalties will be due when individuals file their 2014 tax returns in 2015. The annual penalties for 2014 through 2016 are as follows:

• 2014: Greater of $95 per adult and $47.50 per child under age 18 ($285 maximum per family), or 1% of income over the tax-filing threshold
• 2015: Greater of $325 per adult and $162.50 per child under age 18 ($975 maximum per family), or 2% over the tax-filing threshold
• 2016: Greater of $695 per adult and $347.50 per child under age 18 ($2,085 maximum per family), or 2.5% over the tax-filing threshold

The individual mandate is distinct from the employer mandate, which imposes a fee on most large employers that do not offer a minimum level of coverage. The Administration delayed that provision, putting off the effective date until 2015.
If you have questions about these changes, call us at 1.800.250.2741 or email solutions@gsanational.com.

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DOL Issues Temporary Guidance

According to the temporary guidance, the Notice is applicable to all employers that are subject to the Fair Labor Standards Act (FLSA). This includes most employers, regardless of size. Employers must submit the Notice to all current employees by October 1, 2013, and to new hires within 14 days of their employment start date, at least for 2014.
The Notice must be provided to all full and part time employees in writing and delivered either by mail or email (in accordance with ERISA standards for electronic delivery). Notice must be provided regardless of whether the employer sponsors coverage, or the employee is enrolled in an employer-sponsored medical plan.
The Notice must inform employees that if their plan is not affordable or does not meet minimum value, they may be eligible for a subsidy on the Exchange, otherwise referred to as the Marketplace. If the employer sponsored plan does meet minimum value criteria, the Notice must indicate so by checking the box that states, “If checked, this coverage meets the minimum value standard, and the cost of this coverage to you is intended to be affordable, based on employee wages.”
See our previous post on Exchange Notification Templates for more information.
Employers can confirm whether their plans meet the minimum value criteria by using the Minimum Value Calculatorprovided by the Department of Health and Human Services (HHS).
If you have questions regarding these notifications or require assistance in issuing compliant notifications to your employees, call us at 1.800.250.2741 or email solutions@gsanational.com.

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Lost in the news of the Play or Pay mandate for large employers being delayed is the additional of the Treasury Department announcing that the employer shared responsibility payments of PPACA will be delayed until 2015 as well.
Compliance with the law’s information reporting provisions will be voluntary for 2014, but strongly encouraged. As with the Play or Pay mandate, formal guidance is expected within the next week.
Recognizing that the information reporting required by insurers, employers and others providing health coverage is complex, the administration plans to streamline the requirements process during the delay.
Without the reporting requirements in place, it would be “impractical to determine which employers owe shared responsibility payments,” according to the post on the Treasury Department’s website.
This means there will be no penalties in 2014 on businesses that don’t meet the requirements of the “employer mandate.”
What’s not changing as a result of these delays:

• Employer Responsibility and Information Reporting Requirements
• Exchanges / Marketplaces
• Individual Mandate
• Individuals’ access to premium tax credits
• Any other PPACA provision

If you have questions about these changes, call us at 1.800.250.2741 or email solutions@gsanational.com.

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The Obama administration unexpectedly announced Tuesday that it is delaying the employer mandate under the Patient Protection and Affordable Care Act (PPACA) until 2015. The mandate — which requires mid-sized and large employers to offer health insurance coverage to their workers — was one of the main requirements of the health care overhaul that was set to go into effect Jan. 1, 2014. This will come as a relief to employers as Affordable Care Act (ACA) penalties could amount to as much as $3000 per employee for non-compliance. The delay will allow simplification of reporting requirements by authorities and will give businesses more time to adapt their health insurance policies.
In the coming week, the Treasury department will issue official guidance, with formal rules to be proposed later this summer. We will alert you to any emerging details.
If you have questions about these changes, call us at 1.800.250.2741 or email solutions@gsanational.com.

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The Patient Protection and Affordable Care Act (PPACA) benefit standards for large employers, 50 or more full-time-equivalent employees, have begun taking shape and will differ from those of small employees. To avoid what could amount to be substantial penalties and ensure that health care plans comply with PPACA, employers should model their plans after one of several “safe harbor” designs, which will be developed by the Internal Revenue Service (IRS). All plans offered by large employers must meet standards for “minimum value.”
For a large employer, the plan must cover at least 60% of an employee’s health care costs in a given year – with the employee responsible for the balance through a combination of deductibles, co-pays and co-insurance (often referred to as a “60% actuarial value”).
Large employers can use any of the following to ensure their plans comply with the Affordable Care Act:

• Using the Minimum Value Calculator provided by the Department of Health and Human Services (HHS)
• Using one of several “safe harbor” methods to be defined by HHS – we will communicate guidance once this is established
• Offering a plan that is accepted onto any of the “metal” coverage tiers on a public Health Insurance Exchange. Plans on the public exchanges are categorized into four tiers, from “Bronze” to “Platinum,” with increasing richness of coverage offered.

What does this mean for you, the employer?
You need to make sure that your benefits plans meet the minimum value standard and modify accordingly if they do not. The penalties for non-compliance are $3,000 for each employee who gets coverage and a subsidy through the Exchange.
If you have questions regarding compliance as a large employer, call us at 1.800.250.2741 or emailsolutions@gsanational.com.

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One of the upcoming Affordable Care Act (ACA) action items is the preparation and distribution of a notice to employees about the health insurance exchanges that will become available to individuals starting on January 1, 2014. All employers, including those who do not sponsor a group health plan, must provide a form of the notice to its employees. In addition, all employees must be provided the notice, including those who may not be eligible for employer-sponsored group health plan coverage.
These notices were originally required to be distributed by March 1, 2013. However, the Department of Labor (DOL) delayed this distribution requirement until it had an opportunity to issue further guidance. The DOL has now issued its guidance, and has provided a model notice to be used by employers to comply with their notice obligations. The DOL has issued two model notices: one for employers who do not offer any group health plan coverage, and a second for employers who do offer coverage to some or all of its employees. The guidance issued by the DOL, and the notices, refer to the insurance exchanges as “Marketplaces.”
Notices provided by the DOL for employers who offer group health plan coverage can be downloaded here,http://www.dol.gov/ebsa/pdf/FLSAwithplans.pdf.
Guidance for these notices can be found on the DOL website, http://www.dol.gov/ebsa/newsroom/tr13-02.html.

Key aspects of the Market Notice:

1. Who Must Receive the Marketplace Notice?
   • Employees: All employees must receive the Marketplace Notice, regardless of whether they are eligible to participate in the health plan (such as part-time employees) and regardless of whether they are enrolled in the plan.
   • Dependents: Separate Marketplace Notices are not required to be sent to spouses or dependent children.
   • Former Employees: Marketplace Notices are not required to be sent to former employees, regardless of whether they are still covered by or are eligible for coverage under the plan (e.g., pursuant to COBRA or retiree coverage).
2. When Must the Marketplace Notice Be Delivered?
   • Current Employees: Employees who are on the payroll on or before September 30, 2013 must receive the notice by October 1, 2013.
   • New Employees: New employees hired on or after October 1, 2013 must be provided with a copy of the Marketplace Notice within 14 days of the date of hire. This 14-day period rule is in effect from October 1, 2013 through December 31, 2014. The DOL may modify this in the future.
3. How to Deliver the Marketplace Notice?
   • Mail: The Marketplace Notice may sent via first-class mail.
   • Electronic Delivery: The DOL electronic delivery standards will apply to the Marketplace Notices. Therefore, the Marketplace Notices may be delivered by e-mail to those employees whose work-site access to e-mail is an integral part of the employee’s job duties.
   • New Hire Package The DOL guidance does not expressly state that the Marketplace Notice may be included in a new hire package. But presumably, that would be an acceptable method of delivery for new hires.
4. Required Content of the Marketplace Notice
   As acknowledged in the Department of Labor guidance, the Marketplace Notice is only required to disclose the following:
   • The existence of the Marketplace;
   • A description of services provided by the Marketplace;
   • Contact information for the Marketplace;
   • A statement that the employee may be eligible for a premium tax credit if the employee purchases a qualified health plan through the Marketplace; and
   • A statement that if the employee purchases health coverage through the Marketplace, the employee may lose the contributions made by the employer (if any) toward coverage offered through the employer’s plan, and that all or a portion of the contributions may be excluded from the employee’s income for Federal income tax purposes.

The guidance from the DOL acknowledges that the model is just that – a model, and that employers may use a modified version, provided that it meets the contents requirements set forth above. If you have questions regarding the Marketplace/Insurance Exchange requirements, call 1.800.250.2741 or email us at solutions@gsanational.com to contact one of our Healthcare Reform subject matter specialists.

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