12 Jan Compliance Recap | December 2014
During the month of December Congress passed a temporary increase to the transit pass and vanpooling benefit and the regulatory agencies released several cost-of-living increases, proposed relatively minor revisions to the Summary of Benefits and Coverage (SBC) requirement, and updated the list of counties in which foreign language versions of the SBC and other benefits notices may be required.
Qualified Transportation Benefits
2015 Standard Mileage Rates and Adoption Credit
- 57.5 cents per mile for business miles, up from 56 cents in 2014
- 23 cents per mile for medical or moving purposes, down half a cent from 2014
The adoption tax credit limit will increase to $13,400 in 2015, up from $13,190 in 2014. This credit will again phase out for taxpayers with a high modified adjusted gross income (for 2015 the phase-out will begin at $201,010 and will be completely phased out for taxpayers with a modified adjusted gross income of $241,010 or more; for 2014 the phase-out range was $197,880 to $237,889).
Proposed Changes to Summary of Benefits and Coverage (SBC)
The basic SBC distribution requirements would remain in effect, and a plan administrator that has multiple service providers, such as a major medical provider and a prescription drug provider, would still be allowed to provide multiple SBCs if it notified participants that the SBCs need to be considered together.
Under the proposal, information about the plan’s status as providing minimum essential and minimum value coverage would need to be included on the SBC itself and could no longer be provided separately. The SBC also would be required to state whether elective abortion is covered.
The SBC template itself would be shorter (about five pages compared to the current eight) to allow additional space for plans that need more room to adequately explain their benefits. A new example, involving emergency department care for a foot fracture, would be required, in addition to the current examples of a normal birth and diabetes management. The examples would still be based on figures supplied by HHS, and not actual plan data, although the figures in the HHS calculator have been updated. Most of the deletions from the SBC template involve text, not benefit information. The uniform glossary would be expanded, however.
Comments on the proposed changes are due March 2, 2015, which means that the final version of the template to be used starting this fall likely will not be available until early this summer.
Foreign Language Requirements
Question of the Month
Individuals will not be required to attach proof of coverage, but should maintain evidence of coverage (such as pay stubs showing deductions for premiums or explanations of benefits) in case they are audited. Individuals who did not have the needed coverage for the entire year must use Form 8965 to claim an exemption or determine their penalty (which is determined on a month-by-month basis).
The Marketplace will provide these individuals with a Form 1095-A with information they will need to complete the Form 8962.
Early in 2016, employers that had 50 or more full-time or full-time equivalent employees during 2014, and all insurers and self-funded plans that provided medical coverage during 2015, will first need to provide a report to employees and the IRS about coverage offered and in effect during 2015. That report will be due to the employee by February 1, 2016.
To download the December 2014 Compliance Recap document, click here.