ACA Reporting Update - Lockton€¦ · ACA Reporting Wrinkles (Issues Involving Multiple Lines)...
Transcript of ACA Reporting Update - Lockton€¦ · ACA Reporting Wrinkles (Issues Involving Multiple Lines)...
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HEALTH REFORM ADVISORY PRACTICE
Presented by
Edward Fensholt, J.D.
Scott Behrens, J.D.Compliance Services, Lockton Benefit Group
© Lockton Benefit Group 2016
ACA Reporting Update: What’s Done and Left to be Done, and Where the Bones are (Probably)
Buried
To View Webcast, Click Here
L O C K T O N C O M P A N I E S , L L C
Agenda
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ACA Reporting Issues
Other ACA Issues of Note
Wellness Program Update
What’s Next?
Questions
Agenda
L O C K T O N C O M P A N I E S , L L C
ACA Reporting Issues
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IRS allows a short-term reprieve from ACA reporting deadlines!
Employees may file their tax returns without the 1095-B or -C forms for 2015
What if it turns out the 1095-B or –C is wrong? Employees don’t need to amend their returns if the employees relied on other information supplied by the employer or insurer, about months of coverage in 2015
What other information would the employee rely on?
Memory
Enrollment materials
Payroll deductions
SBC? Exchange notice?
Hip-Hip Reporting Delay!
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Hip-Hip Reporting Delay!
ACA Employer Reporting Requirement
Original Deadline New Deadline
Forms 1095-C to Employees, etc.
Forms 1095-C to full-time employees and to any other employees or primary insureds (retirees, partners, COBRA beneficiaries) with coverage under the employer’s self-insured plan
Feb. 1, 2016(30-day extension available at the
IRS’s discretion)
March 31, 2016(no extension available)
Forms 1094-C and 1095-C to IRS
Paper filing of Forms 1094-C and 1095-C
Feb. 29, 2016(automatic 30-day extension available
via Form 8809)
May 31, 2016(no extension available)
Electronic filing of Forms 1094-C and 1095-C
March 31, 2016(automatic 30-day extension available
via Form 8809)
June 30, 2016(no extension available)
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1. Employers with 50 or more FTEs/FTEqs in 2014 report on their FTEs, in Part II of 1095-C
Why? Prove compliance with employer mandate (or claim an exemption from compliance)
How to count: Aggregate all members of the corporate family tree (controlled/affiliated services group); include bargaining unit employees even if getting coverage through the union
If at least 50 FTEs/FTEqs in the corporate family tree, allmembers of the corporate family tree with separate EINs must report separately, even if – considered alone – the members would be too small to be subject to any of this
If 50-99 FTEs/FTEqs in corporate family tree, no obligation to offer coverage for 2015, but must still report
New law: Allows employer to exclude employees (and their hours of service) receiving TRICARE/VA benefits (applies retroactively to 2014 for 2015 play-or-pay determinations/calculations)
Who does this benefit?
Who Must Report, and Why Are They Doing It?
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2. Each self-funded employer must report on all individuals covered for at least one day in 2015
Why? Help the individual prove compliance with the individual mandate
What if the plan is insured? The insurer will fulfill this obligation, on a Form 1095-B
Employer size doesn’t matter here…whether employer is subject to the employer mandate doesn’t matter…all that matters is that the employer offered self-insured coverage, and somebody took it
What about self-funded HRAs?
What about retiree plans for pre-Medicare-eligible retirees?
What about group Medicare supplemental plans?
Who is covered?
Does it matter which parts of Medicare the retiree is enrolled in?
Who Must Report, and Why Are They Doing It?
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1. Full-time employees (FTEs) for any month of 2015
Why? Employee is basically receiving a copy of the information supplied by the employer to the IRS, to prove compliance with the employer mandate
FTE status is based on either the monthly measurement method or look-back measurement method (an ―ACA FTE‖)
Plan eligibility might not mirror ACA FTE status (e.g., some plans exclude PRNs, temps, interns etc. even though they might be ACA FTEs)…
…So, health plan eligibility is not the benchmark here…ACA FTE status is the benchmark
Mid-year changes in employment status are tricky (see accompanying grid)
Who Gets a Report (i.e., a 1095-C), and Why?
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2. Individuals covered under a self-funded plan for even a single day in 2015…
Why? So they can use the information on the form to prove compliance with the individual mandate
Not just ACA FTEs, but includes part-time employees, retirees, COBRA beneficiaries, partners, directors, contractors, and any others…
…but not individuals covered under a self-insured HRA if the employer sponsors the related medical plan
Doesn’t matter whether the related medical plan is insured or self-funded…the self-insured HRA coverage is not reported
It’s exempted because the reporting of the HRA coverage is redundant, for proving compliance with the individual mandate, with the reporting of the major med coverage
More on HRAs in a few minutes….
Who Gets a Report (i.e., a 1095-C), and Why?
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Don’t send a 1095-C to someone who was never an ACA FTE for even a single month, unless he/she was covered under self-funded plan of the employer for at least a day (but remember: Don’t report the self-insured HRA coverage if the employer sponsors the related insured or self-funded medical plan)
Employees in a “limited non-assessment period” as of Dec. 31 are not FTEs, even if working full-time hours…
New employee in a waiting period
New employee in initial measurement period
First partial month of employment
Self-employed individuals (e.g., partners, contractors, outside directors) are not FTEs
Don’t report on a non-FTE who was offered and declined coverage
Who Doesn’t Get A Report?
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By the Way…How Do We Determine FTE Status for Employees on Leaves of Absence?
FTE status is determined by looking back over the previous month (month-to-month method) or over the previous look-back measurement period (look-back measurement method)
No need to credit hours for workers’ compensationleaves of absence
No need to credit hours for payments under mandated programs under unemployment comp or disability leave laws
No need to credit hours for short- or long-term disability leave unless payments are contributed to by the employer
After-tax payment of premium by employee is not an ―employer contribution‖ for this purpose
What about the employer paying premium, and imputing the cost as taxable income to the employee?
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Which Code Goes Where? (aka ―Form 1095-C, Part II is Hard!‖)
Employee-by-employee, month-by-month determination of whether coverage was offered to an ACA FTE, if not why not, whether it was minimum value (MV) and affordable, and whether the employee was enrolled or not
If you need to report on one month, you need to report on all months Examples:
The non-calendar year delay applies for part of the year
Employee was hired or terminated mid-year (see COBRA discussion, later)
Employee in a FTE stability period for only part of the year
Calendar year reporting, even if plan runs on a non-CY plan year/policy year
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ACA Reporting Wrinkles
COBRA Coverage: An Inconsistent Approach
Final instructions and earlier IRS website posting are inconsistent!
Final instructions themselves treat the approach inconsistently, based on the nature of the qualifying event…
In any event…your COBRA vendor is not responsible for reporting this
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ACA Reporting Wrinkles
Reporting COBRA in Part II, Form 1095-C…
Terminations of FTE Employment
Treat the offer of COBRA as no offer (1H)
Treat enrollment under COBRA as no enrollment (don’t use Code 2C)…instead, show ―Not our employee‖….Code 2A
Reductions in FTE Hours (no termination)
The employee remains active, so use the appropriate coverage offer code on line 14, the cost on line 15, and whether covered or not (or other excuse code, such as 2B (Part-time)) on line 16
Ask first: Am I really stripping eligibility upon the reduction in hours, in the middle of a stability period/plan year, or should I wait to do that?
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ACA Reporting Wrinkles (Issues Involving Multiple Lines)
Reporting COBRA in Part III, Form 1095-C…
Relevant if COBRA is provided under a self-insured plan
Self-insured COBRA coverage is reported in Part III regardless of how the offer is reflected in Part II…thus,
Part II might show Code 1H - No coverage offer - but Part III might show that coverage was supplied
Parts II and III serve different purposes
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ACA Reporting Wrinkles (Issues Involving Multiple Lines)
For Parts II and III (where COBRA is self-insured), distinguish the year in which the termination occurs from the year the individual begins while on COBRA For the year in which the termination occurs,
you’re reporting coverage offers and enrollment etc., up through the first full month after termination, then showing 1H and 2A for remainder of the year…but completing Part III accurately, if enrolled
If the individual began the year on self-insured COBRA, insert Code 1G on line 14, leave lines 15 and 16 blank, and complete Part III
Reminder: If COBRA coverage is insured (employer isn’t
reporting coverage in Part III of the 1095-C) and the covered individual is not an FTE for any month of the year (employer isn’t reporting coverage offers in Part II of the Form 1095-C)…there’s nothing for employer to report
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ACA Reporting Wrinkles (Issues Involving Multiple Lines)
Retroactive Elections Under COBRA…
There can be considerable lag between a COBRA qualifying event and the beneficiary’s election of coverage (and a longer lag before the first month’s payment is due)
Example: Employee terminates Oct. 28, 2015, loses coverage under a self-insured plan. COBRA packet issued early December, former employee elects COBRA in January, makes first premium payment by late February.
COBRA coverage is retroactive
The Form 1095-C should reflect, in Part III, coverage for Oct., Nov. and Dec. 2015
If it doesn’t, need to issue corrected 1095-C
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ACA Reporting Wrinkles (Issues Involving Multiple Lines)
Retiree Coverage: Like COBRA…
Again, distinguish between the year in which the retirement occurs from the year in which the individual is a retiree the entire year…
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ACA Reporting Wrinkles (Issues Involving Multiple Lines)
Mergers and Acquisitions: Who’s on First?
Stock purchases
Asset purchases under a ―successor employer‖ theory, like with W-2s?
Example:
ABC Company acquires XYZ Company (stock purchase) in July 2015; both are subject to employer mandate at time of close
Who reports on XYZ?
What if ABC merges XYZ into ABC?
What if XYZ had been too small for the employer mandate or ACA reporting to apply, at the time of the close?
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ACA Reporting Wrinkles (Issues Involving Multiple Lines)
Reporting Coverage Under an HRA
Generally, avoidable as long as employee is enrolled in another medical plan of the employer, whether insured or self-funded
Both coverages are MEC, but for individual mandate purposes, the IRS only needs to know about one…
Wrinkle: What if the individual is enrolled in the employer’s self-insured HRA, but has coverage under a plan sponsored by a spouse, domestic partner or parent?
Wrinkle: What if employee is enrolled in e’ee-only coverage, and the HRA reimburses dependents’ expenses (dependents may be enrolled elsewhere, or not enrolled at all)?
Wrinkle: What if the HRA is non-integrated?
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ACA Reporting Wrinkles (Issues Involving Multiple Lines)
Reporting Coverage for Bargaining Unit Employees Employer gets a free pass on offering
coverage to full-time bargaining unit employees IF the employer makes contributions on their behalf to a multiemployer plan, and the plan offers MV and affordable coverage to the FTEs, and coverage for their spouses and children
Report as ―no coverage offer‖ (1H) on line 14, skip line 15, and code 2E on line 16, Form 1095-C, Part II
Doesn’t seem to matter whether the employee is actually enrolled in the union plan, or even eligible! (At least not for 2015)
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ACA Reporting Wrinkles (Issues Involving Multiple Lines)
Does the Insurer Know All the Members of the Corporate Family Tree?
Some employers insure all members of the controlled group under a single contract, although there are multiple EINs; each EIN reports to the IRS separately
Some employers sponsor a fully-insured MEWA, covering affiliated but not sufficiently controlled employers; each EIN reports to the IRS separately
Will the ―Employer‖ on the insurer’s Form 1095-B match the ―Employer‖ on the employee’s Form 1095-C
No ―common paymaster‖ rule like there is for W-2s
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ACA Reporting Wrinkles (Issues Involving Multiple Lines)
Working with an ACA Reporting Vendor: Meeting of the Minds
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Generally asks what coverage was offered to the FTE, through the use of 9 different codes (1A – 1I)
Common issues
Coverage must be offered for the entire month to count as an offer for the month (although a failure here is often excused on line 16, with 1 of 9 other codes….)
Distinguish Part III of Form 1095-C and Form 1095-B, for individual mandate purposes
Should I use Code 1A where I can, or not? What if I do?
Code 1A: MV offer to employee, coverage offered to family, employee-only tier is less than 9.56% of the poverty level for the lower 48 states
Why we were not thrilled with Code 1A when first announced
Why we are coming around on the issue…
Line 14 Issues – Coverage Offers
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Amount of the employee’s share of the lowest-cost monthly premium for self-only coverage providing MV
Common issues
Only complete if coverage offer was MV, but don’t complete if 1A or 1I is used
Use the value of the coverage offered, not necessarily the coverage selected
Don’t use the wellness rate even if the employee earned the wellness rate, unless the premium differential relates solely to non-tobacco use…then assume everyone earns the non-tobacco incentive
For 2015, opt-outs/cashable flex credits do not negatively affect affordability
Line 15 Issues – Cost of Coverage
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Line 16 Issues - Penalty Excuses, Affordability Safe Harbors, etc.
Generally explains why the employer shouldn’t be subject to a penalty for failing to offer MV/affordable coverage through the use of 9 different codes (2A – 2I)
Common issues 2C (employee enrolled) trumps other codes in almost
all circumstances (2E applies if collectively bargained transition relief applies, 2A applies for COBRA coverage following termination of employment)
On that note, don’t use 2I (non-calendar year transition relief) unless it is necessary
Affordability safe harbor codes apply only if MV coverage is waived
Line 16 can be left blank (e.g., if an FTE rejects coverage and no safe harbor applies)
Only one affordability safe harbor can apply to any group of similarly situated employees
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IRS Mends the Affordability Safe Harbor ―Disconnect‖
Employer mandate requires offer of ―affordable‖ coverage
Statute: Employee-only coverage shouldn’t cost more than 9.5% of household income
9.56% for 2015, 9.66% for 2016
Employers don’t know what ―household income‖ is for an employee
IRS offers three safe harbors: Don’t ask employee to pay more than 9.5% of:
W-2 pay
Rate of pay x 130 hours
Poverty level for state where employee resides
Disconnect is mended retroactively; safe harbors now inflation-adjusted as well
So, when reporting on Line 16 of 1095-C, use 9.56%to determine whether a safe harbor code applies (9.66% next year)
…Speaking of Affordability…
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…Speaking of Affordability…
HRAs and flex credits might affect affordability calculations in a good way
Might be applied to reduce the amount the employee is asked to pay, for purposes of an affordability calculation
HRAs: If the benefit may be applied only to pay premium, OR to pay premium and reimburse cost sharing
Flex credits: If the credits:
Cannot be taken as cash
Can only be used to buy minimum essential coverage and to reimburse medical care expenses
Generally, this rule will apply after 2016, except for new flex credit programs (will apply to them for 2016)
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…Speaking of Affordability…
EXCEPTION: Service Contract Act and Davis-Bacon Act
At least through 2016, may continue to offer employees choice of fringe contribution as a benefit or as cash, without creating an affordability problem
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…Speaking of Affordability…
A cash opt-out amount will soon be added to the employee's contribution to determine if coverage is affordable
Example: Ed is offered employee-only coverage at a monthly cost of $100. However, if Ed waives coverage, he receives $200 cash. Because the receipt of the cash opt-out credit depends on Ed waiving medical coverage, the IRS concludes that Ed’s ―cost‖ for the medical coverage includes the cash he had to forego in order to enroll in the medical plan.
Thus, in our example, Ed’s monthly cost for employee-only coverage is deemed to be $300 (the $100 per month contribution plus the $200 opt-out ).
Rule applies for plan years beginning on or after January 1, 2017.
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1094-C: Transmittal to the IRS
The primary purpose of the Form 1094-C is for employer to prove compliance with the requirement to offer minimum essential coverage to FTEs and their children (the ―Tier 1‖ or ―aggregate‖ obligation)
Common issues
One 1094-C must be ―authoritative‖ even if various divisions of the same employer submit separate data, or employers sends its 1095-Cs to IRS in batches
Controlled group member? Y/N on line 21, identify months in Part III, identify other members in Part IV
Line 22 is confusing, especially box (c)
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1094-C: Transmittal to the IRS
Line 22
(a) Did the employer make a ―qualifying offer‖ to one or more FTEs?
(b) If one or more employees didn’t get a qualifying offer for one or moremonths, did at least 95% of FTEs receive one?
(c) 4980H Transition Relief:
There’s a lot of transition relief under the employer mandate
This question is asking about two possibilities: 50-99 FTEs/FTEqs in 2014, OR are you ―paying instead of playing‖ and claiming the ―Free 80‖ in your penalty calc?
(d) Did you make an offer of MV and affordable coverage to at least 98% of theemployees for whom you’re preparing a 1095-C?
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1094-C: Transmittal to the IRS
Part III is where the employer attests to Tier 1/‖aggregate‖ compliance on month-by-month basis
Simple Y/N for Column (a)
95% = 70% for 2015
Ignore employees not offered coverage because in a limited non-assessment period
Pretend you offered coverage to bargaining unit members on whose behalf you contributed to a multiemployer plan offering MV/affordable coverage (the ―2E‖ crowd)
Pretend you offered coverage to dependent children even if you didn’t, but were making efforts to install that coverage for 2016
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1094-C: Transmittal to the IRS
FTE Counts for Column (b)
Ignore the same employees ignored in column (a) due to limited non-assessment periods
Free pass on this column if checked box (d) on line 22 – 98% offer method
Total Employee Counts for Column (c)
Count everyone, even part-timers, employees in a limited non-assessment period (i.e., waiting period, initial measurement period and related admin period), etc.
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Reports are due to the IRS by May 31, 2016 if using paper and June 30, 2016 if e-filed
Employers submitting 250 or more reports must e-file unless they obtain a waiver.
Waivers can be claimed on IRS Form 8508 and must be filed by May 16, 2016.
Waivers are not automatic
The e-filing system is cumbersome and requires technical expertise—both with respect to filing out the forms and coding/electronic data transmission/XML
For example . . .
Transmitting Forms to the IRS
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A Form 1094-B that Ends Up Looking Like This . . .
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Is Submitted Looking Like This
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E-Filing Steps
Register to use IRS e-Services
You’ll need at least two people from the employer to do this including at least one responsible official and two contacts (the responsible official can be one of the contacts). Responsible official is an high ranking employee who has authority over the filing process (e.g., president, treasurer, CEO, CFO).
Contact is a person with actually transmits the forms and can respond to IRS inquiries on a day-to-day basis.
Registration requires personal information like SSN, DOB, and adjusted gross income.
Apply for an Information Return Transmitter Control Code (TCC)
Employers can apply as an issuer, transmitter, or software developer
Employers apply for a TCC based on their role:
Issuer – employer is submitting its own returns only
Transmitter – employer is submitting its returns and returns for other employers (e.g., employer submitting for other EINs in the employer’s family tree)
Software Developer – entity designing software for others to use when submitting returns
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Test communications with AIR System
The IRS uses a set of sample fact patterns, which must be converted into XML format and test submitted to confirm that the data transmission will be accurate
Electronically file by June 30, 2016
The IRS AIR Program webpage has numerous resources available including tutorials with screenshots access to webinars and explanations of the various technical requirements
E-Filing Steps
L O C K T O N C O M P A N I E S , L L C
Other ACA Issues of Note
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Employer Mandate – Inflation Adjustments & Transition Relief
Applicable Large Employer (ALE) determinations
50–99 delay expiring
Exclude veterans with TRICARE or VA coverage when counting FTE/FTEqs—this applies to 2014 determinations too
Tier 1 changes
Inflation adjustment to $2,160
Minimum essential coverage must be offered to 95% of full-time employees
―Free 80‖ reduced to ―Free 30‖
Tier 2 changes
Inflation adjustment to $3,240
More to come on affordability determinations
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Cadillac Tax Delay
Delayed to 2020 (from 2018)
40 percent tax on health benefits with values exceeding $10,200 individuals; $27,500 for ―other than individual coverage‖
2020 estimates: $10,950/$29,450
Cadillac tax is deductible
Solves the problem of ―gross up‖ when employer remits tax to insurers and TPAs who then pay IRS
Be heard on this issue!
http://www.fightthe40.com/
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Health Insurer Tax Delay – Medical Device Tax Delay
Health Insurer Tax
Has been in place since 2014
Billions in taxes due from the industry, each insurer pays a portion based on market share, passes along cost in premium charges
2017 Tax Was to Be $13.8 Billion
Delayed one year
Should be no surcharge from carriers for 2017
Medical Device Tax
Has been in place since 2013
Adds 2.3% tax to medical devices except for some at retail outlets
Tax for 2016 and 2017 is delayed
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Auto Enrollment Repeal
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Other Potential Ugliness
Experience Gains Under MEC Programs
Watch your step!
Break in Service Rules
13 weeks for most
26 weeks for educational organizations
IRS: Regs will provide that employees providing services to an educational organization must have a ―meaningful opportunity to provide services‖ for the entire year, or the 26-week rule will apply
L O C K T O N C O M P A N I E S , L L C
Wellness Program Update(No Good Deed Goes Unpunished)
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Wellness Programs Backdrop
Comprehensive HIPAA/ACA Rules
Crafted by IRS, DOL and HHS
Wellness universe has two halves:
Participation-based programs (largely unregulated)
Outcomes-based programs (significant regulation, incentives limited to 30% of cost of coverage, 50% for tobacco-related programs)
EEOC Proposed Rules
ADA: Wellness universe has two halves:
Programs not involving a disability inquiry/medical exam
Programs that do (can’t deny enrollment for not participating, incentives limited to 30% of cost of employee-only coverage)
GINA: Wellness universe has two halves:
Programs not asking for genetic information (family medical history)
Programs that do (can’t ask employee for this at enrollment, or for incentive at any time)
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Wellness Programs and the EEOC
EEOC loses another wellness case Issue centers on health risk assessments and
penalties for not participating
ADA prohibits medical inquiries unless ―voluntary,‖ and voluntary means no ―penalty‖ What’s a penalty?
Does it matter? ADA includes a ―bona fide benefit plan‖ safe harbor or free pass
Proposed EEOC rules prohibit an employer from conditioning coverage on submission to a medical inquiry
EEOC v. Flambeau (W.D. Wis.) – bona fide plan exception allows employer to condition health plan enrollment on employee completing health risk assessment (similar result to Broward County case)
EEOC final regulations on wellness incentives due later this year…what then?
For now, move forward with caution
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Wellness Programs and the EEOC – Part Deux
Genetic Information Nondiscrimination Act Can’t collect genetic information at open
enrollment, or at ANY time in exchange for an incentive
―Genetic information‖ includes family medical history
Response: Wellness vendors stopped asking employees for family medical history
What About Incentives to an Employee, if the Spouse Completes a Health Risk Assessment? The spouse’s information about his/her health is
―family medical history‖ vis-à-vis the employee
EEOC proposed regs: Employers can provide the incentive, but it’s limited, and requires an advance authorization
Cannot ask spouse for his or her family medical history, nor for the children’s
L O C K T O N C O M P A N I E S , L L C
What’s Next?
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U.S. Supreme Court
ERISA preemption of VT all payer claims database (similar to Colorado program)?
Contraceptive mandate requirement to provide HHS or insurer/TPA opt-out form
See attached summary of current landscape)
Issues in a regulatory black hole
New 105(h) regulations
HPID
Things to Look Forward To
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Health Insurance Exchanges – Notice of Employee’s Eligibility for Premium Tax Credit
Sometime later this year, federal exchanges will likely start issuing notices to employers if an employee receives tax credit for exchange coverage
How does the employer demonstrate an offer of coverage?
Employers will have 90 days to dispute ruling
IRS, not the exchange, will assess the penalty
IRS very tight lipped on mechanics of appeals process
Something Not to Look Forward To
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Something Else To Not Look Forward To
HHS to initiate its second round of HIPAA audits
Round #1 was pilot audit program back in 2012
See http://www.hhs.gov/hipaa/for-professionals/compliance-enforcement/audit/index.html
HHS ―wall of shame‖ continues to grow
IRS: If breach, ID protection is tax-free to employees
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Status quo will be maintained if a Democrat wins the White House (or loses the White House but the Republicans lose the Senate)
Big shake ups if Republicans hold the Senate and win the White House? Maybe.
Republicans generally oppose employer and individual mandates, but there doesn’t seem to be a cohesive strategy for how to pay for repeal or what to do instead. Something is bound to happen, but what?
Rubio and Cruz would repeal the ACA and give Americans a tax credit to buy individual coverage (like auto insurance), and across state lines
Trump would repeal the ACA and ―replace it with something terrific‖
Clinton says she’d keep the ACA, but not the Cadillac tax, and she’d control Rx prices and limit cost sharing
Bernie Sanders: ―Spend trillions, go single-payer‖
Our Election 2016 Hot Take
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Our Goal
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www.lockton.com
© 2014 Lockton, Inc. All rights reserved.Images © 2014 Thinkstock. All rights reserved.
Our Mission
To be the worldwide value and service leader in insurance brokerage, risk management, employee benefits, and retirement services
Our Goal
To be the best place to do business and to work
RISK MANAGEMENT | EMPLOYEE BENEFITS | RETIREMENT SERVICES
www.lockton.com
© 2015 Lockton, Inc. All rights reserved.