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With the Supreme Court’s June ruling signifying that the ACA is here to stay, many are now looking ahead to the 2018 Cadillac tax as more of a reality – and its heating up discussions among economists, large corporations, unions, and politicians. In fact, later this month a lobbying group called The Alliance to Fight the Forty is launching to attempt to repeal the tax. And legislation to repeal the tax was introduced by both Republicans and Democrats in the Spring.

On July 6, 2015, the Department of Labor (DOL) issued a proposal to more than double the minimum salary level that white-collar workers must be paid to be exempt from overtime, from $23,660 to $50,400 annually (or from $455/week to $970/week).  With a debate centering around if the proposed salary levels are set correctly (and how future increases will be considered), a public forum for written comments is open until September 4th, 2015.  The proposed amounts are at the 40th percentile of weekly earnings for US employees, and apply only to non-exempt employees (e.g. any employee not considered “executive, administrative or professional”). If approved, the Obama administration says that these changes would impact nearly 5 million US workers within the first year.

In 2016 employers who provide minimum essential coverage to employees will be required to begin mandatory reporting of employee health coverage. In addition applicable large employers (ALEs) will be required to report compliance with the employer shared responsibility provisions (e.g. “pay or play”). To help organizations prepare for new reporting mandates, the IRS is disseminating information around reporting guidelines and penalties.

If your organization sponsors a self-insured plan, you may be on the hook to contribute to the Patient-Centered Outcomes Research Institute (PCORI) Research Trust Fund by July 31, 2015. This fee applies to applicable self-insured plans, including health reimbursement arrangements (HRAs) and flexible spending arrangements (FSAs) that don’t qualify as excepted benefits. In addition, employers who provide COBRA coverage and major medical coverage that falls under multiple policies or plans may also be obligated to contribute to PCORI.

In a previous post, we overviewed three main areas that nonprofits should consider before the 2016 healthcare renewal season begins on November 1: compliance, cost-effectiveness, and employee needs.  In this post, we’ll look more closely at compliance, specifically grandfathered plans, applicable large employer (ALE) status, and new IRS reporting requirements.

As we near the halfway point of 2015, it’s a good time to look ahead to the 2016 healthcare renewal season (open enrollment begins November 1). Specifically, is your current plan 1) in compliance with ACA; 2) cost-effective; and 3) being used to its fullest capacity by employees?  Below is an overview of these three topics, including specific areas to consider as you evaluate the efficacy of your current offerings and decide how to move forward for 2016.

As we approach the mid-way point of the 2015 tax year, it’s a good time to check in on health reform mandates to ensure you are in compliance with ACA.  Whether your organization is fully-insured, self-insured, or partially self-insured, there are a number of mandates that are worth clarifying and confirming as you move forward with your health insurance plans.

With a looming deadline of July 1, 2015 for small businesses to make changes in their premium reimbursement plan practices, it’s a good time to review options for staying in compliance with the ACA.  As background, in previous months the IRS, the Department of Labor (DOL), and Health and Human Services (HHS) all released FAQ around premium reimbursement plans for individual health coverage. Specifically, the FAQs state that premium reimbursement plans, also known as employer payment plans, are out of compliance with the ACA and therefore are subject to heavy excise taxes of up to $100/day for each employee affected.  For one employee, this could mean $36,500/year in fees.