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IntroducBons
Maria Alberts Associate Consultant Alliant Employee Benefits Alphare<a, GA Laura Summers A<orney Ogletree, Deakins, Nash, Smoak & Stewart, P.C. Atlanta, GA
Moderator
Health Care Reform: Whats Ahead? 2016 Birmingham Workshop July 12 - - PowerPoint PPT Presentation
Health Care Reform: Whats Ahead? 2016 Birmingham Workshop July 12 - - PowerPoint PPT Presentation
Health Care Reform: Whats 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
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Agenda
§ Overview § Cadillac Tax § Reporting Requirements § Notice of Premium Tax Credit
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Overview - What’s behind us and what has yet to come
§ Employer mandate – 2015 § Cadillac Tax – 2020 § Employer reporting – 2016
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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
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Cadillac Tax
§ Status
- 2015 guidance
- December 2015 legislation delayed effective date
from 2018 to 2020
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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
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Cadillac Tax
§ Excepted coverage
- Accident or disability insurance
- Workers’ compensation
- Limited purpose plans
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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
- ffered
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Cadillac Tax
§ Notice of calculation of tax § Payment of excise tax
- Payment out of plan assets?
§ Deductibility
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Cadillac Tax
§ Action Items
- Stay up-to-date on changes in the law
- Review long-term benefits strategy and
effects of Cadillac Tax
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Reporting Requirements
§ Purpose - collection of information to:
- Assess individual penalties
- Confirm individual eligibility for subsidies on
Exchanges
- Assess employer mandate penalties
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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
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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)
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Employer Reporting § Enforcement for 2015
- Limited enforcement for
incorrect forms
- Limited relief for late filers
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Employer Reporting § Action items
- Prepare for questions from employees
- Provide coverage verification to employees if
requested (used for tax filing purposes)
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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
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Notice of Premium Tax Credit
´ Appeal rights
´ Timeframe ´ Double check accurate reporting ´ Appeal Request Form 508 ´ Secondary contact
´ Staffing agencies
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Questions?
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Don’t forget your evaluation forms.
Thank You!
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Contact InformaBon
PresentaBon available on SBEN website Speaker A<orney Ogletree, Deakins, Nash, Smoak & Stewart, P.C. Atlanta, GA laura.summers@ogletreedeakins.com 404-870-1713