Page 3 - 2013 EDITION COPE

PLAY MANDATE
PLAY MANDATE
DELAYED
DELAYED
On July 2, 2013, the
Obama Administration
via the Treasury Depart-
ment issued a notice that
enforcement of two key
provisions of Health Care
Reform/PPACA will be
delayed from January 1,
2014 to January 1, 2015.
The two components are
1) that certain employer
reporting requirements
are delayed; and 2) that a
delay in the requirement
for employers with 50 or
more full time equiva-
lents employees offer
affordable, essential
health coverage to all full
time employees working
an average of 30 or more
hours per week or pay a
penalty.
The reasons given for the
delay in enforcement in-
clude recognition of the
difficulty for some em-
ployers to comply with
the provisions, and the
lack of readiness in the
reporting infrastructure.
The hope is that through
voluntary compliance in
2014, the government
will have the opportunity
to test their systems, and
employers will have
more time to comply.
 a
NEW WAITING W WAITING
NE
PER
PERIOD COULD BE IOD COULD BE
TRIC
TRICKY FOR SOME KY FOR SOME
GROUPSOUPS
GR
Just when you thought
you understood a partic-
ular part of the ACA, the
wind changes direction
and a new hurdle ap-
pears.
As you know, the maxi-
mum waiting period for
eligible new hires to be
enrolled in your health
plan is ninety (90) days.
ACA requires that cover-
age begins no more
than the 91st day.
Since many clients main-
tain a waiting period of
first of the month fol-
lowing 90 days or long-
er, the obvious fix is to
move the waiting period
to first of the month fol-
KYC 2 c
Keeping You
Compliant
Assisting Our Clients to Keep
Assisting Our Clients to Keep
in Compliance with HR, DOL
in Compliance with HR, DOL
and PPACA Regulations
and PPACA Regulations
lowing sixty (60) days.
So the alternatives are
NOT SO. There are few for most carriers.
two or three scenari- (1) Drastically shorten
os with dates of hire
your new hire wait pe-
and the effective date riod to 60 days or less,
of coverage where or (2) start coverage on
the coverage will the 91st day, regardless
begin after the 91st of the time of the
day of hire. month.
( (Play Mandate DelayedPlay Mandate Delayed— — Not all car-
c continued)ontinued) “The delay in enforce- riers will
treat this in
REPORTING ment of a key provi- the same
REQUIREMENTS sion provides some
The lack of re- manner, as
porting will mean breathing room some of
that employers
are not required them will
to report to the state only allow a first of
Exchanges which em- the month addition
ployees were offered or deletion.
affordable, essential
health care (affecting
the federal subsidies). Check with your Salus
Employees will be on Group Account Man-
the honor system for ager to see how your
2014 to disclose accu- health insurance car-
rately to Exchange the rier will confirm to
details of their this mandate.
 meet the affordability require-
( (Play Mandate DelayedPlay Mandate Delayed— —
continued)ontinued)
Employers with less than
50 full time equivalent
employees remain un-
affected by the employer
mandate (they were never
required to offer cover-
age).
Nor do these delays
change the planning that
( c (Play Mandate DelayedPlay Mandate Delayed— — time employees, and The biggest short-term many employers have al-
continued)ontinued)
who appeared to be
impact for those em- ready begun to comply
employment and health poised to continue that ployers is that they will and leverage Health Care
practice.
coverage situation. not be required to rede- Reform. This simply gives
fine full time employees employers a longer period
EMPLOYER MANDATE According to an annual as those working an av- with which to align their
survey by the nonprofit
erage of 30 or more benefits with their total
The delay in the employ- Kaiser Family Founda- hours per week (versus rewards strategies to help
er mandate is welcome tion and the Health Re- the traditional 40 hours drive organizational goals
search & Educational
news for some employ-
per week definition).  and objectives.
ers, particularly those in Trust, 98% of employers
construction, retail, res- with more than 200 em- PPACA provides employ-
offer
ployees
health
taurant, and staffing in-
ers with a once-in-a-
dustries. It will likely benefits, and 94% of lifetime opportunity to
have little impact on the those with between 50 fully examine the role of
majority of “large” em-
and 199 employees offer
benefits in their talent ac-
ployers who already insurance. quisition and talent man-
offered coverage to full agement strategies. The
THIS MONTH’S COMPLIANCE QUESTION delay in enforcement of a
key provision provides
some breathing room for
Q: My plan renewal is on 06/01. ment, the answer is 06/01/2014 if you that discussion, but em-
When will it become ACA com- are defined as a small group according ployers should use this
pliant? to ACA. However, all groups, regard- time wisely.
less of size and its renewal date (plan
The requirements are
A: Well, it depends on which year), with begin paying the ACA taxes
part of ACA you are referring and fees beginning with their coming, and employers
to. For the plan to meet all of 01/01/2014 billing cycle. As discussed should be prepared to
its requirements for minimum previous, these taxes and fees will add comply and leverage their
actuarial value, cover all es- approximately 5-6% to your base pre- preparedness and aligned
strategy in advance.
sential health benefits, and mium rate.
— —provided by our friends provided by our friends
at Kushner & Companyt Kushner & Company