Affordable Care Act: Important Reminders for 2015

Now that 2015 has arrived, employers are reminded of the following key changes:

Play or Pay Penalties
January 2015 is the first month for which employers will owe penalties due to failure to provide health insurance meeting the ACA’s standards with respect to availability and affordability/value. Although the effective date for medium-sized employers (50 to 99 employees) was postponed to January 2016, large employers (100 or more employees) do not enjoy this extension, and should be completing their 2015 planning if they have not already done so.

New Reporting Requirements
Related to the above, employers will be required to report information regarding health insurance coverage to employees and to the IRS. Although the first reporting is not due until early 2016 (for the 2015 year), employers need to have structures in place to track the required data for 2015. Draft forms and instructions for this reporting are available on the IRS website at www.irs.gov.

Medical Expense Reimbursement Plans
Also effective January 1, 2014, "stand-alone" HRAs and other medical expense reimbursement plans are no longer permitted. Employers with such plans need to take action to either terminate the plans or provide for integration with the employer’s group health plan. Again, penalties for failure to comply are substantial ($100 per day per employee).

Houston Harbaugh is here to help. If you have any questions or would like assistance in this matter, please do not hesitate to contact your Houston Harbaugh attorney or a member of our ACA Task Force.