Four steps to understand the impact of the ACA

The year 2014 brings new opportunities and challenges for the insured, the uninsured, employees, employers, and employer sponsored health plans. Whether employers continue to provide a health plan in 2014 and beyond may depend on what the employer plan looks like, cost of the plan, what competitors are practicing, and finally, what the political landscape looks like.

Many employers feel it's a competitive advantage to provide a plan to their employees in order to attract and retain key talent. But how can an employer comply with the Affordable Care Act (ACA), engage their employees, and keep their wallets intact? Here are four steps employers should consider to determine the fate of their benefit programs.1. Stay informed.

A few ACA mandates have been delayed and/or will be modified by agencies once they issue final guidance, and an employer's ability to stay up to date is key to remaining competitive.

The "large employer" (50 or more full-time employees) mandate, also known as the "play or pay" mandate has been postponed until 2015. This gives large employers more time to understand the requirement to provide full-time employees and their dependents health insurance and avoid paying a penalty to the government if an employee receives a subsidy when they purchase coverage from a state exchange. We need more guidance to see whether transition relief will be granted to non-calendar year plans (plans renewing on a date other than Jan. 1) that would delay this effective date to the first plan year beginning after Jan. 1, 2015. 

For "applicable large employers" (ALEs) (100 or less full-time employees), the entire Play or Pay mandate is effectively delayed until 2016 provided they are not reducing the size of their workforces to fall under the less than 100 full-time employee threshold and comply with certain maintenance of coverage requirements.

The effective date of the automatic enrollment mandate imposed on employers with more than 200 employees is yet to be determined, as well as the effective date of the nondiscrimination rules applicable to fully insured plans that lost their grandfathered plan status. Those rules would require those insured plans to comply with rules similar to the Internal Revenue Code § 105(h)(2) nondiscrimination rules.2. Understand your immediate compliance deadlines.

There are a number of other ACA changes that take place in 2014 that are not affected by the delay of Play or Pay, and employers must modify their health plans now to be in compliance.

Those changes include a maximum 90-day eligibility waiting period; prohibition on all pre-existing condition limitations; prohibition on dollar caps on essential health benefits; expansion of wellness incentives; dependent coverage up to age 26 (regardless of dependent's access to own coverage); various plan design requirements applicable to non-grandfathered health plans; expiration of waivers for certain limited medical plans and assessments and payments of various ACA-related fees.3. Look for opportunities.

Employers should not let a few rules stop them from exploring creative solutions. Self-funding is a very attractive alternative. Small- to mid-sized employers (50--250 employees) who may have thought that only the largest employers can self-fund are finding their tolerance for risk to be acceptable in this new and changing environment.

Designing a self-funded plan can be made easier with the aid of certified self-funding specialists. It is also a way of offering minimum essential coverage to full time employees, thereby complying with one of the aspects of the ACA.


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