Originally posted August 06, 2013 by Bill Olson on http://analytics.ubabenefits.com
Thomas Jefferson said it best: “Never put off tomorrow what you can do today.” And when it comes to the Patient Protection and Affordable Care Act, this lesson couldn’t ring more true. It’s easy to keep pushing compliance off to a more convenient time, but there are requirements that take effect later this year which demand preparation. The recent PPACA delays, while helpful in some ways, have erroneously caused many to think they can take a sigh of relief for a year.
But oftentimes the reasons for procrastination have to do with not knowing where to start. PPACA requirements are also affected by employer size, which adds further confusion.
The best approach for big projects, such as PPACA compliance, is to have a to-do checklist, especially in our environment where even something as seemingly simple as determining how many employees you have is almost incomprehensible! United Benefit Advisors has developed a PPACA Readiness Checklist that helps employers prepare for upcoming regulations. “Preparing for PPACA – A Readiness Checklist” outlines seven significant requirements, which include:
- All plans that ended between Oct. 1, 2012 and Dec. 31, 2012 must pay the PCORI fee by July 31, 2013.
- All employers covered by the Fair Labor Standards Act (FLSA) must provide a notice about the new health insurance marketplace (also called the affordable care exchange) by Oct. 1, 2013.
- If coverage is offered, regardless of the employer’s size, as of the start of the 2014 plan year, the plan must be updated to include several items.
- If the plan is not a calendar year plan, the employer should decide whether it will allow employees to make mid-year election changes to move from the plan to the exchange/marketplace, and/or to allow employees who previously declined coverage to enroll as of Jan. 1, 2014. (The IRS recently delayed the individual shared responsibility requirement for individuals who are eligible for coverage under an employer-provided, non-calendar year group health plan to the start of the 2014 plan year, so obtaining coverage by Jan. 1, 2014 is not as urgent as previously thought.)
- Although the employer shared responsibility/play or pay requirement has been delayed to 2015, employers should take advantage of this extra time to consider their options. Employers with 50 or more full-time or full-time equivalent employees are considered “large” and will need to offer coverage or pay penalties.
- If the employer is large enough that the shared responsibility requirements will apply in 2015, the employer needs to decide how it will determine which of its employees are “full-time” under PPACA. An employee is considered “full-time” if he or she works an average of 30 or more hours per week.
- If the employer is large enough for employer shared responsibility requirements to apply, the employer needs to decide whether it will offer coverage to its full-time employees, or pay penalties instead.