For the most part, full implementation of the Affordable Care Act (ACA) is here and practices need to understand their obligations under the law. This ‘at-a-glance’ checklist will assist you in understanding your responsibilities to your employees and the impact of ACA on the NCMS Plan.
W-2 Reporting
Uniform Summary of Coverage (SBCs)
Notice of Exchange Eligibility
Employer Mandate
Adult Dependent
Consumer Protections in Insurance
Preventive Benefits
Essential Health Benefits
Wellness Programs
Health Insurer Fee
Temporary Reinsurance Program
Patient-Centered Outcomes Research Institute (PCORI) Fee
Flexible Spending Account Limits
• W-2 Reporting: Practices filing 250 or more W-2s are required to report value of health coverage. Practices filing fewer than 250 W-2s have the option of providing this information or not. Reporting the cost does not mean that the coverage is taxable. The value of the employer’s excludable contribution to health coverage continues to be excludable from an employee’s income, and is not taxable. For more information on W-2 reporting, click here.
• Uniform Summary of Coverage (SBCs): Employees must receive a Uniform Summary of Coverage. The intent is to help eligible employees compare health insurance coverage options before they enroll and understand their coverage once they enroll. The NCMS Plan has made SBCs available on our website. In addition, SBCs are available to active enrolled through the BCBSNC member portal.
• Notice of Exchange Availability: Employees must be provided written notice regarding the availability of Exchange plans and the potential eligibility for subsidies to help pay for health coverage. The annual deadline for providing the notices is October 1st. In September 2013, the USDOL announced that there will be no penalty imposed on employers that fail to distribute the notice. The USDOL’s action essentially makes the notices optional. Click here to access the USDOL’s notification form.
• Employer Mandate (Pay or Play): Assesses a fee of $2,000 per full-time employee, excluding the first 30 employees, on practices with more than 50 employees that do not offer coverage and have at least one full-time employee who receives a premium tax credit. Practices with more than 50 employees that offer coverage but have at least one full-time employee receiving a premium tax credit, will pay the lesser of $3,000 for each employee receiving a premium credit or $2,000 for each full-time employee, excluding the first 30 employees.
This provision has been delayed until January 1, 2015 for businesses with more than 100 employees; delayed until January 1, 2016 for businesses with between 50 and 99 employees.
• Adult Dependent Coverage to Age 26: Extends dependent coverage for adult children up to age 26. The NCMS Plan has been in compliance with this eligibility provision since October 2010.
• Consumer Protections in Insurance: Prohibits group health plans from placing lifetime limits on the dollar value of coverage and from denying coverage based on pre-existing medical conditions or from including pre-existing condition exclusions for eligible employees. The benefit plans offered by the NCMS Plan have always had an unlimited lifetime maximum. The NCMS Plan has never denied coverage to any eligible member based on pre-existing conditions. Pre-existing condition exclusions have not been applied to children since 2010, and the NCMS Plan will eliminate pre-existing condition exclusions for adult members beginning with benefit plan year August 1, 2014 and new and renewal effective dates thereafter.
• Coverage of Preventive Benefits: Requires health plans to provide coverage without cost-sharing for preventive services. Since 2010, the NCMS Plan has been in compliance with this provision providing recommended immunizations, preventive care for infants, children, and adolescents, and additional preventive care and screenings for women, including contraception, with no cost-sharing.
• Essential Health Benefits: Creates an essential health benefits package that provides a comprehensive set of services, limiting annual cost-sharing to the Health Savings Account limits (currently $5,950/individual and $11,900/family).
The NCMS Plan is not subject to the requirement to offer the comprehensive list of services, but we will make a decision as to whether to include these services beginning with plan year August 1, 2014 and new and renewal effective dates thereafter. Services not currently included and under consideration are habilitative, pediatric dental and pediatric vision services.
The NCMS Plan is subject to limits on annual cost-sharing and will make necessary adjustments to plan designs beginning with plan year August 1, 2014 and new and renewal effective dates thereafter.
• Wellness Programs: Permits employers to offer employees rewards of up to 30%, potentially increasing to 50%, of the cost of coverage for participating in a wellness program. For more information on how we can help you with developing compliant wellness programs, contact Jason Horay, Health Promotion Coordinator.
• Health Insurer Fee: A new fee is imposed on health insurers, also known as the Health Insurance Industry Tax. Beginning in 2014, the NCMS Plan will pay an annual fee based on net written premiums. The fee is permanent and will fund premium tax subsidies for low-income individuals and families who purchase insurance through Exchanges. The financial impact to the Plan will be approximately 2.5% of premiums.
• Temporary Reinsurance Program: Creates a temporary reinsurance program to collect payments from health insurers in the group market to provide payments to plans in the individual market that cover high-risk individuals. Though the NCMS Plan will not benefit from this program, we are subject to the payments and will remit payment on behalf of all participating practices. The program runs from January 1, 2014 through December 31, 2016. The reinsurance fee is a per member per month assessment of approximately $5, but will vary. DHHS establishes a formula for payment amounts, and the contributions required of insurers, which must total $25 billion over the three years.
• Patient-Centered Outcomes Research Institute (PCORI) Fee: This fee is imposed on plan sponsors and issuers of group policies. The first year of the fee is $1 per covered life per year, the second year the fee adjusts to $2 per covered life and then it is indexed to national health expenditures thereafter until it ends in 2019. The NCMS Plan is subject to this fee and is responsible for paying this fee on behalf of all participating practices.
• Flexible Spending Account Limits: Limits the amount of contributions to a flexible spending account for medical expenses to $2,500 per year, increased annually by the cost of living adjustment. We can assist you with setting up compliant FSAs and HRAs. Contact your NCMS Plan representative for more information.