Health Care Reform: Whats Ahead? 2016 Birmingham Workshop July 12 - PowerPoint PPT Presentation

Health Care Reform: What’s Ahead? 2016 Birmingham Workshop July 12 10:15am

IntroducBons Maria Alberts Associate Consultant Alliant Employee Benefits Alphare<a, GA Moderator Laura Summers A<orney Ogletree, Deakins, Nash, Smoak & Stewart, P.C. Atlanta, GA

Agenda Overview § Cadillac Tax § Reporting Requirements § Notice of Premium Tax Credit §

Overview - What’s behind us and what has yet to come Employer mandate – 2015 § Cadillac Tax – 2020 § Employer reporting – 2016 §

Cadillac Tax § What it does: • 40% excise tax on differential between the “cost of coverage” and set dollar limits $10,200 per year for self-only coverage ($11,850 for high- § risk occupaQons) $27,500 per year for other-than-self-only ($30,950 for § high-risk occupaQons) Thresholds are indexed to inflaQon (regular inflaQon – not § medical inflaQon) § Policy

Cadillac Tax § Status • 2015 guidance • December 2015 legislation delayed effective date from 2018 to 2020

Cadillac Tax Applicable employer-sponsored coverage” § (1) coverage under a group health plan, (2) that is made • available to an employee by an employer, and (3) is excludable from gross income Types of coverage § Group health plan • Health FSA • Health Reimbursement Arrangement • Retiree-only coverage •

Cadillac Tax § Excepted coverage • Accident or disability insurance • Workers’ compensation • Limited purpose plans

Cadillac Tax § Generally, tax is paid • By insurer (carrier), for insured plan • By employer, for self-insured plan § “Cost of coverage” • Generally, COBRA “applicable premium” • Likely based on benefit package employee is enrolled in, not merely offered

Cadillac Tax Notice of calculation of tax § Payment of excise tax § Payment out of plan assets? • Deductibility §

Cadillac Tax § Action Items • Stay up-to-date on changes in the law • Review long-term benefits strategy and effects of Cadillac Tax

Reporting Requirements § Purpose - collection of information to: • Assess individual penalties • Confirm individual eligibility for subsidies on Exchanges • Assess employer mandate penalties

Reporting Requirements § Who must report? • “Applicable Large Employer” with ≥ 50 FTEs • One ALE can file for others, but each member sQll liable • TPA can file, but employer sQll liable

Employer Reporting § Furnish statement to employees • By January 31 each year • Initial statements for 2015 extended to 3/31/16 § File with IRS • By February 28, or March 31 if filed electronically • Initial filing for 2015 was extended 5/31/16 (or 6/30/16 if filing electronically)

Employer Reporting § Enforcement for 2015 • Limited enforcement for incorrect forms • Limited relief for late filers

Employer Reporting § Action items • Prepare for questions from employees • Provide coverage verification to employees if requested (used for tax filing purposes)

Notice of Premium Tax Credit ´ Starting to roll-out ´ Set up system for collecting ´ Anti-retaliation concerns ´ Log of receipt and timeline ´ State or federal ´ Address ´ Fact gathering

Notice of Premium Tax Credit ´ Appeal rights ´ Timeframe ´ Double check accurate reporting ´ Appeal Request Form 508 ´ Secondary contact ´ Staffing agencies

Questions?

Don’t forget your evaluation forms. Thank You!

Contact InformaBon Speaker A<orney Ogletree, Deakins, Nash, Smoak & Stewart, P.C. Atlanta, GA laura.summers@ogletreedeakins.com 404-870-1713 PresentaBon available on SBEN website