Health Care Reform

Preparing for Health Care Reform

As the Affordable Care Act (ACA) continues to evolve, understanding and complying with federal mandates can be a complex and potentially costly endeavor.  With MMA, you have peace of mind knowing that our team of experts is constantly monitoring and analyzing the reform and the implications for your business.  Our local team, backed by the resources of the industry experts of Marsh & McLennan Agency, is here to help you navigate today and prepare for the future. 

Scope of Services

Based on the needs of your organization, we provide the following services:

  • Analysis of your current plans to determine if you are at risk of triggering penalties for non-compliance, shared responsibility, surcharges or the excise tax
  • Identification of key risk elements and offering of solutions for potential issues
  • A complete reform 'checkup' to make certain you comply with all aspects of regulation
  • An understanding of the financial impact of reform to your business
  • Strategic recommendations to help you better manage your employee benefit plans
  • The ability to help you manage and contain costs associated with ACA
  • Assist with development of employee communication strategies to minimize confusion

Regardless of your industry, size or location, our experts partner with you to understand your long-term plans and needs.  Our team works with you to develop strategies to help you achieve your goals in light of future regulations and reforms.

Resource Center

Welcome the MMA Health Care Reform Resource Center. Included here you will find timely alerts, briefs and resources designed to keep you updated on all the latest Health Care Reform news. MMA is committed to keeping clients informed so they can better prepare for how the law impacts their business and bottom line.

In addition to the Resource Center, MMA has also launched a microsite dedicated to providing employers with the tools and resources  needed to prepare for the changes ahead.  Click here to visit the site and learn more . 

Alerts and Briefs:

President Trump Issues Executive Order on the Affordable Care Act
President Trump moved swiftly after taking office on Friday, issuing an Executive Order intended to minimize the economic and regulatory burdens of the Affordable Care Act (ACA). The order is somewhat symbolic and has no immediate effect on employers, many of whom are in the process of complying with the ACA's onerous reporting requirements (Forms 1094 and 1095), which are not rescinded by the order. Click below PDF to continue reading.

HHS Finalizes 2017 Out-of-Pocket Maximums and Marketplace Guidance
On March 8, 2016, HHS published the final version of its 2017 Notice of Benefit and Payment Parameters. The Notice is issued each year as part of the Affordable Care Act (ACA). For the most part, the guidance is focused on the ACA Marketplaces and insurers offering qualified health plans. It does, however, include several items relevant to employers and group health plans. Click below PDF to continue reading.

Administration Extends Temporary "Fix" for Individual and Small Group Plans
In 2013, the Obama Administration responded to nationwide complaints about health insurance plans being cancelled or not renewed because of the requirements of the Affordable Care Act (ACA) by offering a one-year moratorium on key aspects of the market reform provisions under the Act. That relief was subsequently extended for two years to policy years beginning on or before October 1, 2016 in the small group and individual markets. On February 29, 2016, the relief was once again extended for all non-grandfathered coverage in the individual and small group markets for policy years beginning on or before October 1, 2017, provided that all policies end by December 31, 2017. Click below PDF to continue reading.

Agencies Release New Summary of Benefits and Coverage Templates
Health care reform expands ERISA's disclosure requirements by requiring that a summary of benefits and coverage (SBC) be provided to applicants and enrollees before enrollment or re-enrollment. Specifically, an SBC must be provided at open enrollment, initial enrollment, special enrollment or upon request. The SBCs allow health insurance shoppers to more easily make comparisons among available health plans and assist enrollees to better understand and use their own coverage. Click below PDF to continue reading.

Class Action Lawsuit Alleges Dave & Buster's Reduced Hours to Avoid ACA
The Affordable Care Act exposes applicable large employers to penalties if they do not offer full-time employees health insurance that meets the ACA's minimum value and affordability requirements. One strategy for minimizing exposure to penalties under the employer shared responsibility provisions of the ACA is to minimize the number of "full-time employees," meaning the number of employees working 30 or more hours per week on average. Employers can accomplish this by reducing the number of hours employees work so that they will not be considered to be "full-time" as defined by the ACA, which will require coverage to be offered to fewer employees. Click below PDF to continue reading.

New Agency Guidance and Relief on Offering Student Health Insurance
On Feb. 5, 2016, the Departments of the Treasury, Labor, and Health and Human Services (the Departments) issued a technical release (2016-01) addressing the application of market reforms and other provisions of the Affordable Care Act (ACA) to student health coverage, and providing temporary transition relief from enforcement by the Departments for non-compliant colleges and universities. The release discusses previous guidance which established that employer payment plans (EPPs) (i.e. arrangements that reimburse employees for all or some of the premium expenses incurred for individual market coverage) and health reimbursement arrangements (HRAs) that do the same will fail to comply with certain ACA market reforms; namely, the prohibition on annual dollar limits and the requirement to provide certain preventive services without cost sharing.

Senate Votes to Delay Cadillac Tax
On Friday, December 18, the Senate voted to approve the Protecting Americans From Tax Hikes Act of 2015, which delays for two years the Affordable Care Act's (ACA) excise tax on high cost employer-sponsored health coverage (the "Cadillac tax"). The bill also places a two-year moratorium on the ACA's medical device tax and a one-year moratorium on the ACA's annual fee on health insurers. The President plans to sign the legislation later Friday.

Tax Bill Proposes Cadillac Tax Delay
On Tuesday, December 15, 2015, the U.S. House of Representatives released a tax bill called the Protecting Americans From Tax Hikes Act of 2015, which, if passed into law, will place a two-year moratorium on the Affordable Care Act's (ACA) medical device tax and the excise tax on high cost employer-sponsored health coverage (the "Cadillac tax"), and a one-year moratorium on the ACA's annual fee on health insurers.

PACE Act Allows States to Define Small Group as 50 or Fewer Employees
On October 7, 2015 the President signed the Protecting Affordable Coverage for Employees Act (PACE Act) into law, which amends the Affordable Care Act (ACA) to provide states the flexibility to define a "small employer" for group health insurance purposes as one with 50 or fewer employees on average in the preceding calendar year. States may expand the definition of small employer to include companies with 51 - 100 employees if they wish, although they are no longer required to do so. The PACE Act is a welcome relief to mid-sized employers in the 51-100 employee range who would have been newly reclassified as "small group" for insurance purposes starting in 2016. Click below PDF to continue reading.

IRS Releases Second Notice on Cadillac Tax Implementation Issues
On July 31, 2015, the IRS released Notice 2015-52 (the "Notice"), the second installment in the IRS's process of developing regulatory guidance regarding the ACA's "excise tax on high cost employer-sponsored health coverage" commonly known as the "Cadillac tax." The first piece of IRS guidance on the Cadillac tax was Notice 2015-16, which was released in February 2015. This Notice is intended to supplement Notice 2015-16 by addressing additional issues under the Cadillac tax, including identifying the entities that may be liable for the tax, how to allocate the tax among aggregated entities (e.g., entities within the same tax controlled group), and how to pay the tax. The below PDF summarizes key points from the Notice.

Supreme Court Rules on King v Burwell
In a 6-3 holding released today the United States Supreme Court upheld the availability of subsidies in exchanges maintained by the federal government. Six members of the Court - Chief Justice Roberts, Justices Kennedy, Ginsburg, Breyer, Sotomayor and Kagan voted to validate the Internal Revenue Service's interpretation of the Affordable Care Act ("ACA") that permits premium tax credits in both state- and federally-operated exchanges. This means two things: (i) some 7.5 million Americans will not lose their subsidies that help them to pay for health insurance and (ii) it is back to "business as normal"ÃÂ for the ACA - meaning all employers must continue to attend to their compliance efforts.

IRS Releases Final Forms and Instructions for Affordable Care Act Reporting
In February 2015, the IRS released final forms and instructions related to information reporting under the Affordable Care Act (the "ACA"). These forms include Form 1095-B, Health Coverage, Form 1094-B, Transmittal of Health Coverage Information Returns, Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, and Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage.

New HHS Regulations "Clarify" that Health Plans Covering Families Must Have "Embedded" Individual Cost-Sharing Limits
On February 27, 2015, the Department of Health and Human Services (HHS) released its final HHS Notice of Benefit and Payment Parameters for 2016. The lengthy regulation covers a wide range of topics affecting group health plans, including minimum value, determination of the transitional reinsurance fee, and qualified health plan rates and other market reforms applicable to the group and individual insurance markets.

IRS Releases First Guidance on ACA's So-Called "Cadillac Tax"
Last week, the IRS released Notice 2015-16 in an effort to begin developing regulatory guidance for the Affordable Care Act's excise tax on high-cost health coverage (the "Excise Tax"), which will become effective beginning as early as 2018. The Excise Tax, which is commonly referred to as the "Cadillac Tax," imposes a 40% nondeductible excise tax on the aggregate cost of an applicable employer-sponsored coverage (including employer-sponsored group health plan and multiemployer plan coverage) in excess of certain statutory limits. Although the Notice does not provide any definitive answers to the many questions raised, it is still welcome news in that it identifies a number of issues that could be addressed in forthcoming guidance and, in some cases, indicates the direction in which the IRS is headed. This can help many employers and plan sponsors as they now consider steps to mitigate possible exposure to the Excise Tax. This is especially true for employers contributing to multiemployer health plans who bargain benefit levels, as they may have only one more opportunity at the bargaining table to adjust benefits before the Excise Tax applies.

Transitional Reinsurance Fee Reporting Extended
On Friday, November 14, CMS extended the November 17, 2014 deadline for contributing entities (employers with self-insured medical plans) to submit their 2014 enrollment counts for the transitional reinsurance program. The deadline has been extended until 11:59 p.m. on Friday, December 5, 2014. The January 15, 2015 and November 15, 2015 payment deadlines remain the same. As a reminder, employers that sponsor self-insured major medical plans must report their annual enrollment count to the U.S. Department of Health and Human Services via the pay.gov website by December 5, 2014, as part of the ACA's transitional reinsurance program.

IRS to Close Loophole on Sub-Standard Plans without Hospitalization or Physician Services Coverage
On November 4, 2014, the Internal Revenue Service (IRS) announced that it intends to close a perceived "loophole" in health care reform. This so-called loophole allows employers to offer low cost health plans that don't cover inpatient hospitalization services or physician services (or both). If that coverage were treated as minimum value coverage, then employers could avoid all pay-or-play penalties with low cost coverage and covered individuals would not be able to benefit from premium assistance or subsidies in the health insurance Marketplace.

CMS Announces Delayed Enforcement of HPID Requirement
On October 31st, CMS announced that it is delaying "until further notice" its enforcement of the regulation requiring health plans and other HIPAA-covered entities to obtain and use health plan identifiers (HPIDs). The full announcement can be found using the link below. This means that employers and other sponsors of self-insured group health plans will not be required to obtain an HPID by November 5, 2014.

IRS Increases Maximum Employee Contribution to Health Care FSAs for 2015
The IRS announced late last week that the maximum annual employee contribution to a health care flexible spending account plan is increasing by $50 to $2,550 for 2015 (up from the $2,500 limit that has applied since 2013).

Your ACA Preparation Tool
To help employers with the challenges of the Affordable Care Act, MMA has introduced a new ACA preparation tool.

HPID Reminder: Health Plans Required to Register by November 5, 2014
As part of the Affordable Care Act's (ACA) Administrative Simplification provision, all controlling health plans (defined below) must obtain a 10-digit numeric identifier known as a Health Plan Identifier, or HPID. The HPID is part of a project that federal agencies, health insurers and health care provider groups have been working on for years, as final rules for the HPID requirement were published in the Federal Register on September 5, 2012 (77 FR 54719) (the Final Rules).

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