Employee Benefits Series - 2015 Benefit Notices
Update: Effective January 9th, 2014, the Obama Administration delayed the Employer Mandate (Large Employer) until January 1st, 2016.
All companies who sponsor a group health plan and have a full time employee count over 50, you are subject to the Pay or Play Mandate. Here is an additional twist, if you do choose to provide health insurance, but it does not cover the Essential Health Benefits as mandated by ACA or pay for at least 60% of covered health care expenses, your employees will have the option to shop the Exchange and receive a tax credit. Knowing this is the tip of the iceberg for meeting compliance needs.
- For employers with 100+ Full Time Employees (FTEs) or equivalents, the entire mandate is delayed until January 1st, 2015 or for non-calendar year plans (and meet certain criteria) first day of the sponsor’s 2015 plan year - numerous requirements apply in order to qualify for the delay.
- For employers with 50 - 99 Full Time Employees (FTEs) or equivalents, the entire mandate is delayed until January 1st, 2016 or for non-calendar year plans (and meet certain criteria) first day of the sponsor’s 2016 plan year - numerous requirements apply in order to qualify for the delay.
Final Rule Regarding ACA 90-Day Waiting Period Limitation - The final regulations require that no group health plan or group health insurance issuer impose a waiting period that exceeds 90 days after an employee is otherwise eligible for coverage. The rules do not require coverage be offered to any particular individual or class of individuals. To ensure that eligibility conditions based solely on the passage of time are not used to evade the waiting period limit, the rules state that such conditions cannot exceed 90 days. Other conditions for eligibility are generally permissible, such as meeting certain sales goals, earning a certain level of commission, or successfully completing an orientation period.
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