coverage

Individual Mandate and the March 31 Deadline

Info for Part-time or Other Employees Currently Without Health Insurance

There’s lots of noise out there related to Obamacare’s individual mandate and the rapidly approaching March 31 open enrollment deadline. Here’s summary information for those part-time or other employees that currently do not have any health insurance:

  • The deadline to sign up for individual health insurance is March 31 – less than a week away. This marks the end of the open enrollment period.  After March 31, those without coverage will not be able to purchase an individual health plan (on or off the exchange) until the next open enrollment period beginning in November — unless they have a qualifying event such as marriage, birth of a child, loss of employer sponsored health coverage, move out of state, have a significant income change, etc.  If that’s the case, then they can enroll during a special enrollment period.
  • Extensions may be available based on information released just yesterday.  According to latest reports if someone started to apply for coverage through the HealthCare.gov website but could not finish by March 31 or they experienced other glitches in trying to sign up, they will have until about the middle of April to seek an extension.  Individuals can qualify for an extension by checking a blue box on the HealthCare.gov website indicating that they’ve tried to enroll before the deadline. The following are links to recent news stories that reported the extension that was officially announced yesterday:

http://www.reuters.com/article/2014/03/26/usa-healthcare-enrollment-idUSL1N0MN04Y20140326

http://www.thefiscaltimes.com/Articles/2014/03/25/White-House-Extends-Enrollment-Time-Obamacare

  • If someone goes without health coverage after March 31, they may be subject to health reform law’s tax penalty come tax time next April for not having coverage.  The penalty this year is $95 or up to 1% of income, whichever is greater.
  • Some financial assistance may be available.  Individuals and families with incomes between 100 percent and 400 percent of the poverty level (about $11,490 to $45,960 for individuals) may qualify of premium tax credits (also referred to as premium subsidies).  Tax credits are based on a percentage of household income and are applied on a sliding scale for those that qualify.

Individuals who want to obtain health care insurance before the March 31 deadline should visit Healthare.gov to begin their application process.

Your employees. Are they medicaid eligible?

There are many opinions about Medicaid expansion and my post is opinion free.

Employers across all sectors of the economy are likely to have Medicaid eligible employees/dependents in their population. Many do not know they are Medicaid eligible and some may be on the employer plan.

What does this mean?

Like anything, researching it may be the best first step. Simply finding out if this exists in an employer population may make sense.

Then what?

Some employees will be delighted to know they qualify, some may be upset. Some employers will take advantage of Medicaid expansion to reduce the rolls on the employer-sponsored plan while others may hate the idea and avoid it all together.

We respect all opinions but we also are developing a tool to determine eligibility and — if the employer would like — assist in the enrollment process. We will be launching it next month.

We want to help any employer that wants to know who in their population is eligible for Medicaid and then listen to find out if there is anything the employer would like to do about it.

What is Medicaid?

  • Medicaid is funded largely by the federal government but run by the states
  • Unlike Medicare, Medicaid eligibility is based on income.  The Affordable Care Act expanded medicaid to reach well beyond prior eligibility pools (it will now 133% of poverty level).
  • Medicaid operates as nearly 100% coverage for all medical expenses.
  • Medicaid networks are more restrictive than Medicare or commercial policy networks
Medicaid used to be accessible only to children and low (really low) income parents with dependent children. Single people did not qualify. Parents with eligible children did not qualify often. Eligibility now is much much wider.
In the next few weeks we will be rolling out a tool to assist any employer/employee evaluate Medicaid eligibility.

More Changes / Delays to the Employer Mandate

3 Employer Take-a-ways

The administration announced late Monday yet another change-up to one of the major focal points embedded in the Affordable Care Act  –  the employer mandate. Here are the three biggest aspects of the announcement that employers of all sizes need to know:

Employers with 100+ Employees

Employers with 100 or more workers will only have to cover 70% (down from 95%) of eligible employees in 2015 to avoid fines. The original 95% benchmark now goes into effect in 2016 and beyond.

Employers with 50 – 100 Employees

Employers in this category get a reprieve of sorts through 2015 as the mandate is delayed altogether for another year. As things stand today, they must begin offering coverage to eligible employees in 2016 in order to avoid fines associated with the new law.

Employers with fewer than 50 Employees

Under 50 employers (already exempt from the employer mandate to provide coverage) will now be exempt in 2015 and each year going forward from the reporting requirements they were subject to as originally outlined in the new law.

Despite speculation by many, as of yet there have been no changes or reprieves to the individual mandate that went into effect on January 1 of this year. It remains unchanged.

For more detailed information on Monday’s announcement see articles that appeared in the Washington Post and Fiscal Times

For an expert analysis, read Bob Laszewski’s piece at Health Care Policy and Marketplace Review.

ACA October 1 Notice of Coverage Mandatory for Employers

DOL Update Confirms No Penalties for Non-Compliance

As part of the implementation of the Affordable Care Act, Health and Human Services (HHS) is requiring that all employers distribute to their employees basic information related to the new Federally Facilitated Healthcare Exchange or Marketplace that is scheduled to be introduced on October 1, 2013.  While the details of the exchanges still have yet to be released, the requirement for employers to notify their employees remains in effect.

Official rules defining compliance have not been issued. HHS, however, has issued guidelines. Here’s a net of those guidelines:

  • Applies to employers that employ one or more employees and generate annual revenue of $500,000 or more.
  • Employers must provide a notice of coverage options to each employee, regardless of plan enrollment status (if applicable) or of part-time or full-time status.
  • The notice must include information regarding the existence of a new Marketplace and contact information and description of the services provided by a Marketplace. It must inform the employee that he/she may be eligible for a premium tax credit if the employee purchases a qualified health plan through the Marketplace; and inform the employee that if the employee purchases a plan via the Marketplace, they may lose the employer contribution (if any) to any health benefits plan offered by the employer; and, that all or a portion of such contribution may be excludable from income for Federal income tax purposes.
  • Employers are required to provide the notice to ALL current employees not later than October 1, 2013.  In 2014, any new employees are to be provided a notice within 14 days of an employee’s start date.   It may be provided electronically.
  • Model language is available on the DOL’s website.  Employers may use it or a modified version, provided the notice meets the content requirements described above.

Complete details can be found on the DOL website http://www.dol.gov/ebsa/newsroom/tr13-02.html

Our take on the bottom line is this:  Even though details of the exchanges have not yet been released, HHS is requiring all employers to distribute by October 1, 2013 an announcement to all employees regarding the upcoming open enrollment for the Federally Facilitated Healthcare Exchange or Marketplace – regardless of each employee’s employment or plan enrollment status.  However, and contrary to some of the fear mongering opportunists kicking up dust in and around the market, in a recently released FAQ the DOL clarified that while employers should provide a written notice to all employees about the Health Insurance Marketplace by October 1, 2013, there is no fine or penalty under the law for failing to provide the notice .

www.dol.gov/ebsa/faqs/faq-noticeofcoverageoptions.html

We will try and keep you posted on any new developments.

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