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Employer Pay or Play Penalty Delay
January 1, 2015
Individual Mandate Penalty Still
April 1, 2014
New Delay Announced under the Affordable Care Act
Employers will have more time to
Offer or not offer health coverage
Select Insurance Plan(s)
Develop pricing and implementation strategy
Test to minimize possible future penalty under Pay or Play
No Delay for Employers
Health Plans must still meet all other requirements such as 90 day waiting periods and no pre-existing condition clauses
Notification requirements such as Summary Benefits Coverage (SBC) and Exchange Availability Notice
Honor System for Individuals
IRS won’t be able to determine if the employee has affordable and minimum value health care coverage
Indications are that individuals will also self-attest to income for 2014 to get subsidy and verification may be difficult
Lack of Reporting from Employer and Individual Self-Reporting May lead to some individuals getting a premium tax credit when they are not eligible
Impact to Individuals
Could lead to a tax liability when they file their taxes at the end of 2014 and/or disenrollment from the plan they have selected in 2015
Impact to Employers
State Exchanges may want to verify employer coverage directly instead of accepting individuals’ word
Employees will want to know what to do
Employees on exchange in 2014 could trigger $3,000 penalty in 2015 if they remain in the exchange.
What can an Employer do to reduce the confusion?
Communicate Now
Is our plan considered affordable?
It is, so you should answer yes to the question on employer coverage
Consider Using Exchange Notice Due on October 1, 2014
We will not offer health insurance in 2014
We will offer affordable and minimum value health insurance in 2014
To High-Light type of Health Insurance that will be available in 2014
The Best News for Employers is there will be more time to get it right without a penalty
If you found this information valuable, then please pass it on!
Thank you!
www.bclsystems.net