E to E...by Employers for Employers E to E provides information from a business perspective that will educate regional employers about significant healthcare issues to help them make decisions benefiting their organizations and employees.

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February 2016 Issue

Contents

ACA Compliance Tips For 2016

ACA Need To Know: Important Dates Moved Back

Consumer-Driven Health Plans May Hold Appeal To Employers

Patient-Focused Healthcare Apps Help Employees

Quick Poll – Review

February Quick Poll – Vote

Contact Information

NIHP Home

ACA COMPLIANCE TIPS FOR 2016

As anticipated, complying with the Affordable Care Act (ACA) will require time, tenacity, and "new tooling" in 2016. Make sure you have a plan to file required paperwork and meet upcoming deadlines. The reminders, below, will help keep you organized and avoid potential fines.

Applicable Large Employer (ALE) Status
Employers need to determine whether they meet the definition of "applicable large employer" (ALE) in 2016 based on 2015 employee data. An employer is now deemed an ALE if it employed an average of at least 50 full-time employees (as that term is defined under the ACA) and the IRS will expect the business to file employees' coverage accordingly in 2016. Employee counts include conversion of part-time employees into full-time equivalents and rules for employment.

Forms 1095-C and 1094-C must be filed no later than Feb. 28, 2016, or by March 31, 2016, if filing electronically. Ensure filings include your business's name as well as the name of the employee receiving the health insurance and how long his or her medical coverage will last under the plan. Also be sure to send your employees a copy of their 1095-C form. The Society for Human Resource Management advises mailing this form by Feb. 1, 2016.

2015 Transitional Reinsurance Fee
You may have already handled the 2015 transitional reinsurance fee contribution of $44 per covered life if you paid in full by January 15, 2016. Or you may have chosen to pay in two installments—the first installment ($33 per covered life) due on January 15, 2016, and the second ($11 per covered life) due on November 15, 2016. If you have not yet filed your first installment, give us a call and we can quickly help you decide how to handle this fee.

2015 Patient-Centered Outcome Research Institute (PCORI) Fee
July 31, 2016 is the date the 2015 PCORI fee of $2.17 per covered life is due for the 2015 plan year. The insurer is required to report and pay the PCORI fee on fully insured products.


FURTHER READING

ACA outlook: What will 2016 hold for the Affordable Care Act and employers?, JD Supra Business Advisor, December 31, 2015

Group health plan action items and reminders for the new year, Morgan Lewis, January 5, 2016

What you need to know for ACA compliance 2016, Sage Advice, January 2016



ACA Need To Know: Important Dates Moved Back

Rollout dates for ACA compliance have recently been delayed in two important areas, giving employers like you some breathing room as you organize for 2016 and beyond.

• "Cadillac Tax" Delay
On December 18, President Obama signed the Consolidated Appropriations Act, delaying the start of the ACA’s "Cadillac Tax" on high-value plans by two years – until January 1, 2020. Additionally, the Cadillac Tax will now also be deductible, indexing of the Cadillac Tax thresholds will start in 2018, and the controller general is ordered to study the underlying age and gender adjustments to the Cadillac Tax.

Congress also expressed a strong bipartisan desire to abolish the Cadillac Tax, which was intended to both raise revenue to pay for the ACA's premium subsidies and to reduce the cost of health care. It is mostly unpopular with both unions and employers, so more changes could be on the way. Although the possibility of its elimination remains, employers should continue planning for the 2020 deadline.

• Reporting Due Date Extension for IRS Code Sections 6055 and 6056
The Department of the Treasury and the IRS have determined that some employers, insurers, and other providers of minimum essential coverage need additional time to file their form 1095.

Notice 2016-4 extends the due dates for the 2015 information reporting requirements (both furnishing to individuals and filing with the Internal Revenue Service) under section 6055 of the Internal Revenue Code, and the information reporting requirements for applicable large employers under section 6056 of the Code.

Specifically, this notice extends the due date:

  1. for furnishing to individuals the 2015 Form 1095-B, Health Coverage, and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from February 1, 2016, to March 31, 2016, and
  2. for filing with the Service the 2015 Form 1094-B, Transmittal of Health Coverage Information Returns, the 2015 Form 1095-B, Health Coverage, the 2015 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and the 2015 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, from February 29, 2016, to May 31, 2016, if not filing electronically, and from March 31, 2016, to June 30, 2016, if filing electronically.

This notice also provides guidance to individuals who might not receive a Form 1095-B or Form 1095-C by the time they file their 2015 tax returns.

The Service is prepared to accept filings of the information returns on Forms 1094-B, 1095-B, 1094-C, and 1095-C beginning in January 2016 and employers and other coverage providers are encouraged to furnish statements and file the information returns as soon as they are ready. Those who do not meet the extended due dates are subject to penalties.

For a copy of the Notice 2016-4, please click here.


FURTHER READING

'Cadillac' tax delayed: What it means for HR pros, HR Morning, December 23, 2015

Employer groups want more than two-year delay to Cadillac tax, Employee Benefit Adviser, December 18, 2015

IRS extends due dates for reporting of some healthcare coverage, Forbes, December 29, 2015

IRS extends health care information return due dates, Journal of Accountancy, January 4, 2016



Consumer-Driven Health Plans May Hold Appeal To Employers

Consumer-driven health plans, which often include health reimbursement accounts and health savings accounts, are normally high-deductible medical plans joined with a tax-deferred savings or spending account. Employees can use those funds to pay portions of their health care costs.

Recent studies from groups such as EBRI/Greenwald indicate that consumer-driven health plans seem to be encouraging cost-conscious behavior and involvement in wellness programs. Opponents of the plans, however, urge caution. Harvard economist Amitabh Chandra suggests that patients in such plans reduce their use of prescribed drugs, skip preventive services, and end up spending more in the long term. "Simply calling a patient a consumer doesn’t make buying healthcare like buying cars," she says.

This makes communications especially important. According to T. Doherty, president of Pinnacle HR Solutions in Needham, Massachusetts, more employers will introduce consumer-driven health plans in 2016, which will make employee education a top priority. "Traditional paper-based communication efforts won’t be enough — top-performing employers will expand communication via mobile and web-based platforms," he says. Depending on your workforce demographics, Doherty’s premise is especially spot-on.

If you are interested in finding out more about the pros and cons of a consumer-driven health plan for your business, we will be happy to discuss your options in more detail. Call or e-mail us to set up a meeting.


FURTHER READING

Consumer-driven healthcare may finally be getting traction, HR Drive, December 23, 2015

The myth of 'consumer-driven healthcare' comes to life again, LA Times, January 6, 2016

Study: Consumer-driven health plans on the horizon, articlehealthnews.com, December 30, 2015



Patient-Focused Healthcare Apps Help Employees

Consider these smart phone apps that can help your employees with the basics of good health care.

  • Medisafe – Offering a "virtual pillbox," the app reminds users exactly when to take their prescription medications, how much of each to take, and educates them about their conditions. Cost is free.
  • YouPlus – The YouPlus mobile app provides daily lifestyle coaching to make healthy living easier. It includes science-driven exercise programs, meal recommendations for at-home or restaurant dining, and more. Cost is free.

Do you have a healthcare-specific app you'd like to recommend to our readers? Let us know!



A Quick Review of Last Issue's "Quick Poll"

In the October 2015 issue of E to E we asked readers, "Do you know your ACA number?" Specific survey results are noted in the chart, below.

October Quick-Poll Summary



February Quick Poll – Vote

Are you using, or have you considered switching to, a consumer-driven health plan?
(Click a response to vote. Answers are strictly anonymous.)

Then, visit the NIHP website to view this issue's quick poll results.




For more information contact us at:
(800) 723-0202 or NIHPCustomerService@nihp.com

Northern Illinois Health Plan

773 W. Lincoln Blvd., Suite 402, Freeport, IL 61032

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