Compliance Alert: Health Care Provisions Effective in 2015—Are you Prepared?

Important Affordable Care Act (ACA) implementation and enforcement deadlines—such as for the employer mandate ("pay or play") and information reporting requirements—are approaching quickly. Make sure you are prepared by taking advantage of the resources ABC is offering, including a recent webinar on how these complex ACA requirements could impact your company in 2015.  

To watch the webinar and review the PowerPoint, visit ABC’s Health Care Law Employer Toolkit (log-in required). The toolkit offers small and large members access to reference guides, webinars and power points, regulatory guidance, and much more.

Employer Mandate (Pay or Play) 
Effective in 2015, employers with 100 or more full-time employees and full-time equivalent employees must offer full-time employees a certain level of health coverage or be subject to a penalty. 
  • Detailed guidance about complying with the employer mandate is available here.
  • An overview of key ACA provisions for employers with 50 or more employees is available here
Additional information about the employer requirements under ACA can be found on ABC’s Health Care Law Employer Toolkit.
  
Exceptions 
Employers with 50 to 99 full-time employees and full-time equivalents are not required to comply with the employer mandate until 2016 (provided they meet certain IRS certification requirements). However, such employers are subject to the information reporting requirements under Internal Revenue Code (IRC) sections 6055 and 6056 beginning in 2015.
  • An overview of key ACA provisions for employers with 50 or more employees is available here
Employers with fewer than 50 full-time employees and full-time equivalents do not have to comply with the employer mandate. However, small employer health plans are required to cover “essential health benefits” (effective 2014). Further, small employers that self-insure will be subject to IRC section 6055 beginning in 2015.  
  • An overview of key ACA provisions for employers with up to 50 employees is available here.
  • An overview of key ACA provisions for employers with fewer than 25 employees is available here.
Information Reporting Requirements 
The ACA also includes onerous employer reporting requirements. Beginning in 2015, employers with 50 or more full-time employees and full-time-equivalent employees—as well as employers of any size that self-insure—are required to report certain information about the type of health insurance coverage offered (IRC sections 6055 and 6056) to the Internal Revenue Service (IRS). Employers must collect the information required to be reported beginning in 2015 and file the information reporting returns with the IRS in 2016. In addition to filing information returns with the IRS, an employer must provide a related statement to each full-time employee under section 6056 and to each covered individual under 6055.
  • Applicable large employers (50 or more full-time employees and full-time-equivalent employees) can learn more about section 6056, here.  
  • Self-insuring employers (of any size) can learn more about 6055, here
*Employers are encouraged to consult counsel and/or their insurance brokers about complying with ACA in 2015 and beyond.