Administrative Requirements

Health Care Reform imposes several new administrative requirements in connection with employer-sponsored coverage.

Click on any of the following to learn more.

W-2 Reporting

Employers must report the value of employer-sponsored health care coverage on employee W-2 Forms. Reporting is required for most employers beginning with the 2012 tax year.

Summary of Benefits and Coverage and the Uniform Glossary

Plan sponsors must provide two new government-developed documents to plan participants beginning with enrollments on or after September 23, 2012 - the "Summary of Benefits and Coverage" (SBC) and the "Uniform Glossary," which are intended to provide high-level descriptions of a plan and definitions of standard terms.

 

30 Day Enrollment

Plans must offer a minimum of 30 days for open enrollment for the first plan year beginning on or after September 23, 2010.

Automatic Enrollment

Employer-plan sponsors with more than 200 full-time employees must automatically enroll their employees in an employer-sponsored health plan. The effective date for this provision is expected to be established by federal regulations.

 

Quality Reporting

Plan sponsors of non-grandfathered plans must report on plan benefits and reimbursement structures that provide certain quality-related programs like disease management. Future regulations are expected to clarify the content and effective date.

Coverage and Workforce Reporting

Effective January 1, 2015, employers with 50 or more full-time employees must submit reports to the IRS with extensive details about the employer's health coverage and workforce.  Coverage reporting is also required for any plan sponsors that provide minimum essential coverage.

 

Cadillac Tax Reporting

Effective January 1, 2018, employers will be required to calculate and report the amount of the excise tax, if any, that is owed with regard to their health plans.

Patient Protection Notices

By the first day of the first plan year beginning on or after September 23, 2010, plan sponsors must provide certain notices to employees in connection with the requirements to eliminate any lifetime limits, extend eligibility to adult children, and provide direct access to certain providers.

 

Transparency Disclosures

Non-grandfathered plans must provide certain information to HHS and the public, such as claims payment, enrollment, and financial data. Future regulations are epxected to clarify the content and effective date.

Advance Notice of Benefit Changes

Effective September 23, 2012 if any mid-year material modifications in health plan coverage, such as increases in cost-sharing or benefit reductions, are made that are not reflected in the most recently distributed Summary of Benefits and Coverage (SBC), the plan sponsor must send notice of the changes to plan participants at least 60 days before the modifications become effective.

 

Employee Exchange Notice

Employers must provide information about the state Exchanges to all full-time and part-time employees by October 1, 2013 and upon hire for new employees after October 1, 2013.

Nondiscrimination Testing

In order to ensure compliance with the new nondiscrimination rules for insured, non-grandfathered plans, employers may be required to perform nondiscrimination testing.

 

Additional Medicare Tax

Effective January 1, 2013, employers must withhold an additional 0.9% Medicare tax on wages paid to employees in excess of $200,000.

American Fidelity Assurance Company does not provide tax or legal advice.

ESB-844(1211)

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