Larry Lawman, RHU Kathy Hargreaves, CPA/CFP/CPC Melanie J

Larry Lawman, RHU!
Kathy Hargreaves, CPA/CFP/CPC!
Melanie J. Hancock!
Principal!
Lawman Benefits Consulting!
Shareholder!
Kerkering, Barberio & Co.!
Partner!
Hill Ward Henderson!
SEMINAR SERIES!
On March 23, 2010, the Patient Protection and Affordable Care
Act (ACA) and the Health Care and Education Affordability
Reconciliation Act of 2010 were signed into law.!
Who does it effect?!
Employers!
Providers!
Individuals
& Families!
Insurance
Companies!
Pharma &
Medical Device
Manufacturers!
SEMINAR SERIES!
Law does not require employers to offer health coverage
nor for individuals be covered!
•  Large employers that do not offer affordable coverage
that has a required minimum value to full-time
employees (and their dependents) may be subject to a
penalty!
•  Small employers may be able to qualify for certain tax
subsidies!
•  All employers are subject to new rules and prohibitions!
•  Individuals who are not covered by a Qualified Health
Plan may be subject to a tax penalty!
SEMINAR SERIES!
A closer look at the impact on all employers...!
Benefits!
IT/Systems!
Unknown!
Legal!
Payroll/Time!
Human
Resources!
Tax!
Finance!
SEMINAR SERIES!
A closer look at the impact on all employers...!
Waiting Periods!
Non-discrimination!
Reimbursing Individual Premiums!
Standardized Benefits!
Premium and Cost Increases!
Notice of Exchange!
Wai$ng Periods SEMINAR SERIES!
Wai$ng Periods cannot exceed 90 days, Eﬀec$ve as of plan years beginning on or a<er January 1, 2014 • 
The $me that must pass before coverage for an individual who is otherwise eligible to enroll in a health plan becomes eﬀec$ve • 
If an individual enrolls as a late enrollee or special enrollee, any $me before such late or special enrollment is not a wai$ng period Wai$ng Periods SEMINAR SERIES •  All calendar days are counted beginning on the enrollment date, including weekends and holidays •  90 days does not equal 3 months! •  Compliance does not mean the “1st of the month following 90 days” •  Plan will not have violated the wai$ng period rules merely because individuals may take addi$onal $me (beyond the end of the wai$ng period) to elect coverage •  Beneﬁt-‐speciﬁc wai$ng periods may be permiWed, subject to an “an$-‐abuse rule” Wai$ng Periods SEMINAR SERIES •  If eligibility is based on a cumula$ve hrs of service, the hrs-‐of-‐service requirement cannot exceed 1,200 hrs –  The plan’s wai$ng period must begin on the ﬁrst day a<er the employee sa$sﬁes the cumula$ve hrs-‐of-‐service requirement and may not exceed 90 days –  This is a one-‐$me eligibility requirement only; re-‐applica$on of such a requirement to the same individual each year is not permiWed –  Plan provisions that base eligibility on whether an employee is, for example, mee$ng certain sales goals or earning a certain level of commission, are generally substan$ve eligibility provisions that would not trigger the 90-‐day wai$ng period limita$on Wai$ng Periods SEMINAR SERIES Wai$ng period starts when an employee is “otherwise eligible to enroll” in a plan –  met the plan’s substan$ve eligibility condi$ons •  eligible job classiﬁca$on •  achieving job-‐related licensure requirements speciﬁed in the plan’s terms •  sa$sfac$on of a reasonable and bona ﬁde employment-‐based orienta$on period –  One month is maximum length –  Employer should undertake an evalua$on process rela$ng to the employment situa$on during the orienta$on period and document any orienta$on and training processes Wai$ng Periods SEMINAR SERIES •  Example: Company’s group health plan provides that only employees who have completed speciﬁed training and achieved speciﬁed cer$ﬁca$ons are eligible for coverage under the plan. Paul is hired on May 3 and meets the plan’s eligibility criteria on September 22. –  In this example, Paul becomes eligible for coverage on September 22, but for the wai$ng period. Any wai$ng period for Paul would begin on September 22 and may not exceed 90 days; therefore, coverage under Company’s plan must become eﬀec$ve no later than December 21. Non-‐Discrimina$on SEMINAR SERIES What is Non-‐discriminaCon? Highly compensated individuals may not receive a beWer beneﬁt in terms of eligibility or beneﬁt Eligibility: A plan generally must beneﬁt at least 70% of all employees Beneﬁt: A plan must provide the same beneﬁts to non-‐highly compensated par$cipants that are provided to highly compensated individuals (HCI’s) Non-‐Discrimina$on PenalCes • 
• 
• 
• 
Excise tax of $100 for each day in the noncompliance period for each individual to whom such failure relates $100 for each day per individual for each day that the plan does not comply with the requirement Ability for a civil ac$on Enforcement is suspended pending further guidance. SEMINAR SERIES Standardized Beneﬁts SEMINAR SERIES QUALIFIED PLAN LEVELS Details on Actuarial Value More than just coinsurance PLATINUM: 90% of cost GOLD: 80% of cost SILVER: 70% of cost BRONZE: 60% of cost Catastrophic (Individual Only) Up to age 30 / exempt from mandate Standardized Beneﬁts Summary of Beneﬁts and Coverage (SBC) What Is It? •  Uniform descrip$on of the coverage (all cost share items, such as, copays, deduc$bles, coinsurance) •  Must follow speciﬁc format •  May not be longer than 4 pages, double-‐side, 12 point font. SEMINAR SERIES Standardized Beneﬁts SEMINAR SERIES Summary of Beneﬁts and Coverage (SBC) When/How Are They Delivered? •  Employer responsibility to ensure all employees and beneﬁciaries receive them •  Distribute at ini$al and open enrollment, and no later than 7 days when request by a plan par$cipant •  Deliver to HIPAA special enrollees within 7 days upon request for enrollment •  May be delivered in paper format or electronic, if electronic delivery rules are met (safe harbor) Standardized Beneﬁts Summary of Beneﬁts and Coverage (SBC) Penalty For Non-‐Compliance •  A health plan that willingly fails to provide an SBC will be subject to a ﬁne of up to $1,000 for each failure •  A failure with respect to each par$cipant and beneﬁciary is a separate oﬀense SEMINAR SERIES The Marketplace (aka Exchange) SEMINAR SERIES Types of Exchanges: 1.  State-‐owned and Operated 2.  State-‐Federal Partnership 3.  Federal (Healthcare.gov) 4.  Private The Marketplace (aka Exchange) SEMINAR SERIES What are the funcCons of Exchanges? •  Oﬀer a choice of health plans •  Assign quality and price ra$ngs •  Create assessment tools for consumers •  Operate a website and call center to provide compara$ve informa$on and allow individuals to purchase coverage •  Serve as a neutral party that can oﬀer consumer assistance in enrollment, informa$on and subsidy determina$on No$ce of Exchange SEMINAR SERIES NoCfy Employees of Exchanges •  Must be given to all current employees prior to October 2014. •  WriWen into the Fair Labor Standards Act (FLSA). •  For 2015, the Department will consider a no$ce to be provided at the $me of hiring if the no$ce is provided within 14 days of an employee’s start date. •  To no$fy employees of the existence of the Marketplace. That federal subsidies may be available. That an employee could lose their employer’s contribu$on, if any, toward their cost of coverage. Premium & Cost Impact 1.  Health Insurer Fee (HIF) 2.  ComparaCve EﬀecCveness Research Fee 3.  Reinsurance Fee 4.  Medical Device and PharmaceuCcal Taxes 5.  Fair Health Insurance Premiums SEMINAR SERIES Premium & Cost Impact SEMINAR SERIES SEMINAR SERIES Premium & Cost Impact Blue Op$ons plan before the ACA Ages 30 -‐ 54 Males Females $235 $254 Por$on of Monthly Health Plan Cost due to the ACA Cost of new beneﬁts that must be covered Cost to cover pre-‐exis$ng condi$ons New fees and taxes the carrier must pay Change to 3 : 1 ra$o for age -‐$43 $143 $22 $10 -‐$21 $134 $22 -‐$23 Dollar Diﬀerence in Health Plan Costs Percentage Diﬀerence in Health Plan Costs $132 56.3% $113 44.4% Blue Op$ons plan a3er the ACA $367 $366 SEMINAR SERIES Large Employers Large Employers SEMINAR SERIES Who is an Applicable Large Employer (ALE)? •  For-‐proﬁt, non-‐proﬁt, governmental employers that employed, on average, 50 FTEs (full $me equivalents) during the preceding calendar year •  Full $me is stated at 30 hours per week •  Part $me employees must be added to determine FTEs Large Employers SEMINAR SERIES ACA deﬁnes a large employer is an employer who has 50 or more full-‐
$me employees or full-‐$me equivalents for preceding year: •  Full-‐$me employees: those that work 30 or more hours a week calculated on a monthly basis •  Full-‐$me equivalents (total hours/120) •  If workforce exceeded 50 FT employees for 120 days or fewer and the excess was seasonal employees then not a large employer Large Employers SEMINAR SERIES •  ABC Company has 45 employees who work 30 hours per week or more. They also employ 7 part $me employees. •  The full $me equivalency of the 7 part $me employees must be added to the 45 full $me employees. •  Add the total number of part $me hours worked in a month and divide by 120. •  Example: Each part $me employee worked 80 hours in the month of January. 80 x 7 = 560 / 120 = 4.66 (truncate) •  ABC Company has 49 FTEs for the month of January Large Employers SEMINAR SERIES Types of Employees 1.  Current or incoming employees who are paid at least 30 hours per week 2.  Current or incoming employees who are paid below 30 hours in a week 3. Ongoing or incoming variable-‐hour employees whose hours of work ﬂuctuate above and below 30 hours per week Large Employers SEMINAR SERIES •  Coun$ng hours of service -‐ actual hours paid –  Equivalency methods if not paid hourly – 8 hour days or 40 hours per week, unless this would substan$ally understate hours •  Employers must assume new variable-‐hour employees will work for en$re ini$al measurement period, star$ng in 2015 Large Employers SEMINAR SERIES •  The regula$ons imply that the determina$on be made monthly •  Monthly approach imprac$cal •  IRS released safe harbor to determine full-‐$me employees –  Apply “measurement periods” where $me is counted, and the determina$on of status during that measurement period will hold for “stability period” Large Employers SEMINAR SERIES •  Common law employees •  The penalty only applies with respect to full-‐$me employees working 30 hours per week and 130 hours per month, not full-‐$me equivalents •  Hours “paid or en$tled to payment” –  Bona Fide Volunteer hours not counted –  Students in federal work-‐study programs excluded –  Adjunct faculty: can use 2.25 hrs for each hr teaching –  On call hrs: if paid for them, probably have to count Large Employers SEMINAR SERIES •  A “seasonal employee” is an employee in a posi$on for which the customary annual employment is six months or less –  Customary length of the posi$on not the $me for which the person is hired –  Treated like a variable hour employee, even if works more than 30 hrs/wk when hired •  If your seasonal employee does not meet the deﬁni$on of “seasonal”, are they a variable hour employee or full-‐$me employee Large Employers SEMINAR SERIES Temporary staﬃng or PEO – Who is the employer? •  Depends on rela$onship between staﬃng agency, worker and client employer •  If employee is a common law employee of the agency’s client, but the staﬃng agency oﬀers coverage on behalf of its client, it will be considered an oﬀer of coverage by the client –  To evidence this, client must pay an extra amount to the staﬃng agency for employees enrolling in the agency’s coverage Large Employers SEMINAR SERIES Measurement Period (“Look back period”): Employers can select a ﬁxed 3 to 12-‐month period to determine weather an employee has worked an average of 30 hours per week Stability Period (“coverage period”): If an employee averages 30 hours a week in the measurement period they must be treated as full $me (regardless of the actual hours worked) during this period. Cannot be shorter than 6 months or shorter than the measurement period. AdministraCve Period (OpConal): Up to a 90-‐day period between measurement and stability periods for employers to decide which employees must be oﬀered coverage Large Employers SEMINAR SERIES •  Measurement period must be uniform for employees in same category –  Collec$ve bargaining agreements –  Non-‐collec$vely bargained –  Salaried –  Hourly –  Primary place of employment in diﬀerent states •  Change in hours during the year does not eﬀect status throughout stability period, but change in employment status to non-‐variable does Large Employers SEMINAR SERIES Safe harbor for new variable and seasonal employees: • 
Apply an ini$al measurement period (IMP) of 3 to 12 months • 
IMP plus administra$ve period cannot extend more than 13 months from hire • 
Stability period must be at least 6 consecu$ve months, not be shorter than the IMP and begin a<er the IMP Large Employers SEMINAR SERIES Special rules rela$ng to rehires A.  An employee will be considered to have terminated employment (and may be treated as a new employee upon return) if the employee has a period of 13 consecu$ve weeks during which the employee is not credited with an hour of service (26 weeks for educa$onal ins$tu$ons) B.  Op$onal rule of parity (must be at least 4 weeks): For example, if a 4-‐
wk rule of parity is applied, an employee who works for ﬁve weeks and then has no credited hours for six weeks may be treated as a new employee. This allows an employer to treat an employee as terminated following absences shorter than 13 weeks (or 26 weeks for educa$onal organiza$ons). Large Employers SEMINAR SERIES Can we simply reduce an employees hours to part $me and avoid the ACA issues? What about changing status from employees to independent contractors? •  Poten$al issues –  ERISA 510 Claims –  Misclassiﬁca$on of employees Large Employers SEMINAR SERIES Shared Responsibility Rules: Mandates •  Large employers (with 50 FTEs or greater) are required to either: 1.  Oﬀer minimum essen$al coverage that is aﬀordable and provide minimum value to full $me employees and their dependents, or 2.  Pay an Excise Tax if at least one full $me employee receives federal assistance to purchase health coverage on an Exchange. •  No Excise Tax applies if the minimum essen$al coverage oﬀered is aﬀordable and provides minimum value. Large Employers Employer Mandate PenalCes IRC 4980H(a) •  If at least 95% (70% for 2015) of all full $me employees (and their dependents) are NOT oﬀered coverage and one full $me employee obtains coverage through the exchange and receives Federal assistance: –  Penalty per month is 1/12 of $2,000 (indexed) mul$plied by the number of full-‐$me employees not taking into account the ﬁrst 30 (80 for 2015) SEMINAR SERIES Large Employers Employer Mandate PenalCes IRC 4980H(b) •  If at least 95% (70% for 2015) of all full $me employees (and their dependents) are oﬀered coverage and one full $me employee not oﬀered coverage obtains coverage through the exchange and receives Federal assistance: –  Penalty per month is 1/12 of $3,000 (indexed) mul$plied by the number of full-‐$me employees receiving assistance on exchange –  Cannot exceed no coverage penalty SEMINAR SERIES Large Employers Employer Mandate PenalCes IRC 4980H(b) •  $3000 penalty also applies if the health coverage oﬀered is deemed not aﬀordable or pays for less than 60% of covered health care expenses •  IRS safe harbor – “aﬀordable” if premium contribu$on for single coverage does not exceed: –  9.5% of employee’s W-‐2 wages (9.56% for 2015) –  9.5% of federal poverty limit –  9.5% of the computed monthly rate of pay SEMINAR SERIES Large Employers SEMINAR SERIES Employer Mandate TransiCon Relief for 2015 Employers with 50-‐99 full-‐$me employees and full-‐$me equivalents during 2014 will not be subject to the employer mandate for any calendar month during 2015 or any calendar month during the por$on of the 2015 plan year that falls in 2016 if: A.  During the period beginning on 2/9/14 and ending on 12/31/14, the employer does not –  Reduce the size of its workforce or –  Reduce the overall hours of service of its employees in order to sa$sfy the workforce size condi$on –  Bona ﬁde reasons OK Large Employers SEMINAR SERIES Employer Mandate TransiCon Relief for 2015 B.  During the period 2/9/14 -‐ 12/31/14: •  Employer does not eliminate or materially reduce health coverage •  employer contribu$on to coverage that is at least 95% of the dollar amount of the contribu$on on 2/9/14 or •  Is the same or a higher percentage of the cost of coverage that the employer was oﬀering to contribute on 2/9/14 •  If beneﬁts change under employee-‐only coverage, coverage provides minimum value a<er the change; AND employer does not alter plan to narrow classes of employees or dependents oﬀered coverage Large Employers SEMINAR SERIES Employer Mandate TransiCon Relief for 2015 •  Example: On February 9, 2014, employer contributed $300/mo for coverage that costs $400/mo. for employee-‐only. Cost increases to $425 –  Employer con$nues to contribute $300/mo. = OK •  Employer must cer$fy it met requirements as part of its repor$ng Large Employers SEMINAR SERIES Employer Mandate TransiCon Relief for 2015 •  One year delay in requirement to oﬀer coverage to full-‐$me employees’ dependents –  Employers that did not previously oﬀer dependent coverage but are taking steps to arrange for such coverage to begin in 2016 –  Also applies to dependent coverage that does not cons$tute minimum essen$al coverage or dependent coverage oﬀered for only some dependents –  Not available to the extent dependent coverage had been oﬀered during either the 2013 or 2014 plan year and coverage oﬀer was subsequently dropped Large Employers SEMINAR SERIES Special ConsideraCons Related Employers •  Controlled Group/Aﬃliated Service Group and determina$on of “large” employer •  Applica$on of Penal$es: –  Penal$es are applied separately to each related en$ty but the exclusion of the ﬁrst 30 employees (or 80 for employers with 100 or more employees in 2015) is prorated •  Diﬀerent controlled group members can use diﬀerent measurement periods Large Employers SEMINAR SERIES Plan ReporCng under ACA; Sec. 6056 •  Repor$ng is required beginning in early 2016 to report coverage provided in 2015 •  Employers must prepare separate returns for individuals, furnish the individuals with copies of the returns and use a single transmiWal form to ﬁle the individual informa$on returns with the IRS •  Timing of repor$ng is similar to Form W-‐2 •  For ﬁling the return and transmiWal with the IRS, the deadline is 2/28 (3/31 if ﬁled electronically) of the following year •  Those subject to transi$on rules get relief for 2015 •  Penal$es for non-‐repor$ng Large Employers SEMINAR SERIES Plan ReporCng under ACA; Sec. 6055 •  If provide minimum essen$al coverage to an individual during a calendar year, must report certain health insurance coverage informa$on to the IRS •  Must also provide a wriWen statement to the covered individual •  Insurer Is Repor$ng En$ty for Employer-‐Sponsored Insured Group Health Plans A.  Form 1094-‐C – Employer transmiWal B.  Form 1095-‐C – Employee statements Large Employers SEMINAR SERIES Pay or Play: Economic ConsideraCons •  Cost to provide coverage vs. cost of penalty a)  Number of employees b)  Cost of current insurance c)  Cadillac tax • 
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Increase in the penal$es over $me for employers and individuals Eﬀect on workers compensa$on Cost of coverage through the Exchange Loss of premium deduc$bility Large Employers SEMINAR SERIES Pay or Play: Noneconomic ConsideraCons • 
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Company culture Employee expecta$ons Industry standards and compe$$on Unions •  Types of coverage op$ons available through the Exchange •  Demographics of workforce •  Individual shared responsibility penal$es SEMINAR SERIES Small Employers Individuals & Families Small Employers SEMINAR SERIES Small Business Health OpCons Program (SHOP) 3 requirements an employer must sa$sfy: • 
The employer has no more than 25 full $me equivalent employees for the tax year • 
FTEs average annual wages cannot exceed $50,000 for tax years • 
The employer’s non-‐elec$ve contribu$on arrangement must meet the requirements of Code 45R • 
Transi$onal rules for 2014 • 
50% tax credit Reimbursing Individual Premiums SEMINAR SERIES Sec 105 Medical Reimbursement Plan • 
• 
Only available as a stand alone plan if there is only one employee Can be combined with group health insurance if more than one employee Premium Payment Plans (PPP) Premium Funding Plan (PFP) Premium Reimbursement Arrangement (PRA) Reimbursing Individual Premiums SEMINAR SERIES Reimbursing Individual Premiums SEMINAR SERIES What if an employer reimburses employees for premiums they pay for health insurance either through a qualiﬁed plan or through the Marketplace? Per IRS No$ce 2013-‐54, these employer payment plans are considered to be group health plans subject to the market reforms, including the prohibi$on on annual limits for essen$al health beneﬁts and the requirement to provide certain preven$ve care without cost sharing. Such arrangements cannot be integrated with individual policies to sa$sfy the market reforms. Consequently, such an arrangement fails to sa$sfy the market reforms. Reimbursing Individual Premiums PenalCes May be subject to a $100/day excise tax per applicable employee (which is $36,500 per year, per employee) under sec$on 4980D of the Internal Revenue Code. SEMINAR SERIES Individuals & Families SEMINAR SERIES Individuals must be enrolled in a qualiﬁed plan or pay an excise tax; pay greater of 2014: $95 per person (capped at $285 per family) or 1% of income over the tax ﬁling threshold 2015: $325 per person (capped at $975 per family) or 2% of income over the tax ﬁling threshold 2016: $695 per person (capped at $2085 per family) or 2.5% of income over the tax ﬁling threshold Assessed penalty for dependents is half the individual rate Individuals & Families SEMINAR SERIES Minimum essenCal coverage includes: Medicare Part A, Medicaid, Tricare Insurance purchased through an Exchange, on the individual market CHIP Employer-‐sponsored coverage Certain types of Veterans health coverage Individuals & Families CalculaCng the Penalty A.  Lesser of the monthly penalty amount or B.  Sum of the monthly na$onal average premium for bronze level qualiﬁed plans that provide coverage SEMINAR SERIES Individuals & Families SEMINAR SERIES Example Kathy and John have household income of $100,000, and they have one son, Jeﬀ, age 13 Household income is $100,000 Threshold ﬁling requirement is $20,300 Excess income is $100,000-‐$20,300=$79,700 * .01=797.7 The Hargreaves will pay a penalty of (95x2)=190 + 47.50=257.50 or Penalty is $797.7 (greater of ) Individuals & Families SEMINAR SERIES ExempCons from paying the penalty 1.  You’re uninsured for less than 3 months of the year 2.  The lowest-‐priced coverage available to you would cost more than 8% of your household income 3.  You don’t have to ﬁle a tax return because your income is too low 4.  You’re a member of a federally recognized tribe or eligible for services through an Indian Health Services provider 5.  You’re a member of a recognized health care sharing ministry 6.  You’re a member of a recognized religious sect with religious objec$ons to insurance, including Social Security and Medicare 7.  You’re incarcerated and not being held pending disposi$on of charges 8.  You’re not lawfully present in the U.S. Individuals & Families SEMINAR SERIES Hardship ExempCons (not inclusive) 1.  You were homeless. 2. 
3. 
4. 
5. 
You were evicted in the past 6 months or were facing evic$on or foreclosure. You received a shut-‐oﬀ no$ce from a u$lity company. You recently experienced domes$c violence. You recently experienced the death of a close family member. 6.  You experienced a ﬁre, ﬂood, or other natural or human-‐caused disaster that caused substan$al damage to your property. 7.  You ﬁled for bankruptcy in the last 6 months. 8.  You experienced unexpected increases in necessary expenses due to caring for an ill, disabled, or aging family member. 9.  Your individual insurance plan was cancelled and you believe other Marketplace plans are unaﬀordable. Individuals & Families Premium Assistance Credit (Refundable Credit) Eligibility •  Proof that individual does not have access to aﬀordable employer-‐sponsored health insurance coverage of a minimum value (9.5% of household income) •  Don’t confuse with the 8% test for individual penalty SEMINAR SERIES Individuals & Families SEMINAR SERIES AGI + Exclusions like tax exempt interest, nontaxable social security beneﬁts = Household Income Individuals & Families SEMINAR SERIES Assistance for Eligible individuals Premium assistance credit: Income is 100% but not more than 400% of the Federal Poverty Level “FPL” •  Computed based on the premium cost for a benchmark plan (second lowest cost silver plan) •  Delivered as a credit in advance by paying the premium Cost sharing reducCon subsidy: Addi$onal-‐ For individuals and families who make <250% of the FPL and enroll a in silver-‐level plan Coverage is considered aﬀordable for this purpose if the premium for self only coverage does not exceed 9.5% SEMINAR SERIES Employee Premium as % W2 Wages Box 1 400% OF FPL = $94,200 IN 2013 HOUSEHOLD INCOME FOR A FAMILY OF 4 400% OF FPL = $45,960 IN 2013 HOUSEHOLD INCOME FOR AN INDIVIDUAL Eligible for Tax Subsidy Under 9.5% 0% -‐ 138% FPL 139 % -‐ 400% FPL 400% FPL + SEMINAR SERIES Individuals & Families 2013/2014 Annual Federal Poverty Guidelines Household Size 100% 133% 150% 200% 300% 400% 1 $11,490 $15,282 $17,235 $22,980 $34,470 $45,960 2 15,510 20,628 23,265 31,020 46,530 62,040 3 19,530 25,975 29,295 39,060 58,590 78,120 4 23,550 31,322 35,325 47,100 70,650 94,200 5 27,570 36,668 41,355 55,140 82,710 110,280 6 31,590 42,015 47,385 63,180 94,770 126,360 7 35,610 47,361 53,415 71,220 106,830 142,440 8 39,630 52,708 59,445 79,260 118,890 158,520 For each additional
person, add $4,020 $5,347 $6,030 $8,040 $12,060 $16,080 Individuals & Families SEMINAR SERIES Individuals & Families SEMINAR SERIES Example Kathy and John have household income of $100,000, and they are each employed •  Household income is $100,000 •  Health insurance for Kathy is $5,000 •  Health insurance John is $5,000 •  Neither Kathy or John will qualify for an unaﬀordable exemp$on because each health insurance premium is aﬀordable (100,000*.
08=8,000) May qualify for hardship SEMINAR SERIES Summary/Next Steps Summary/Next Steps SEMINAR SERIES •  Determine poten$al impacts of penal$es •  Establish procedures for determining and documen$ng full-‐$me employees •  Iden$fy whether plans are aﬀordable and oﬀer minimum coverage •  Amend plans to address your decisions regarding compliance a)  Eligibility provisions b)  Wai$ng periods c)  Measurement periods Special Considera$ons: Advisor / Consultant Rela$onships SEMINAR SERIES •  Appoint an internal team to review and make decisions regarding the ACA requirements •  Look back and stability periods •  Review employee demographics, i.e. Seasonal, Temporary, Variable •  Evaluate the pay or play rules •  Hire the necessary consultants •  Determine the length of the “season” to see if you have seasonal employees •  Review any temporary staﬃng agreement
SEMINAR SERIES Ques$ons

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