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This year marks the first year applicable large employers (ALE; 50+ full time or full-time equivalent employees) are required to report employer-sponsored healthcare coverage to the IRS and provide statements to full-time employees under IRS Sections 6055 and 6056.  To help circumvent common misperceptions and errors, this two-part blog series will look at: 1) what needs to be reported, what forms need to be used, and who needs to comply with reporting requirements; and 2) methods of reporting, deadlines, and penalty relief.

The 2016 tax season may seem far away, but with numerous changes in the works for organizations that offer group health coverage, its actually the ideal time to start planning for ACA reporting.  Previous blog posts have shared information around reporting requirements and the release of draft forms and penalty fees from the IRS.

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.

Despite the fact that the PPACA is meant to lower healthcare costs, a new report from TransUnion Healthcareshows that consumer out-of-pocket expenses have actually increased 11% from 2013 to 2014, while at the same time deductibles have risen by 7% and revolving credit has declined.  Specifically, according to TransUnion the ratio of revolving credit to healthcare costs has decreased from 15.2:1 in 2013 to 13.5:1 in 2014, but out-of-pocket expenses have increased by almost $250 (from $2245 to $2491).  This means that consumers have less money available to pay for ever-increasing healthcare costs.

On April 20, 2015, the Equal Employment Opportunity Commission (EEOC) proposed new rules around employee wellness programs, especially as they relate to the Americans with Disabilities Act (ADA).  Specifically the proposed rules provide further clarification around what constitutes a “voluntary” program, how incentives can be used, confidentiality of medical information, and accommodations for those employees who are unable to participate in an incentivized wellness program.