Enrolling employees for the 2014 company health plan will put plan managers to a test like they’ve never seen before. Those that haven’t already immersed themselves in the details are going to be working some very late nights in the next couple of weeks.
John Haslinger, vice president for strategic advisory services at ADP, helped BenefitsPro.com compile a list of the essentials that must be executed in order to comply with the law and avoid sanctions.
Haslinger strongly advises that companies take these requirements seriously. He said the government’s decision to delay the corporate plan sanctions piece of the PPACA until 2015 doesn’t let anyone off the hook as far as meeting all the other requirements by Jan. 1. And many items must be completed by Oct. 1.
Here, then, are nine items you need to check off your 2014 checklist to stay out of the PPACA’s woodshed.
1. Notice of coverage or exchange notification: It’s up to employers to notify every employee, covered by a company health plan or not, of the health care options available to them through the insurance exchanges created by the Patient Protection and Affordable Care Act. This notification must be in an employee’s hands no later than Oct. 1. Employers hired after Oct. 1 have to be notified within 14 days.
Suggestion: If you haven’t started this process, hire a third-party administrator with knowledge of the process to do it for you.
2. The Transitional Reinsurance Fee: This is the $63-per-covered-member fee that plan sponsors and insurers must pay. The money goes to fund insurance for high-risk individuals. Employers and insurers have to report their enrollment numbers to the feds by Nov. 15. You’ll get an invoice back in a month, if all goes as planned, and the bill will come due a month later.
Suggestion: Set aside a good chunk of dough now to cover the cost.
3. Essential health benefits: This section of the PPACA requires non-grandfathered health plans to cover 10 essential health benefits as follows:
(1) ambulatory patient services; (2) emergency services; (3) hospitalization; (4) maternity and newborn care; (5) mental health and substance use disorder services including behavioral health treatment; (6) prescription drugs; (7) rehabilitative and habilitative services and devices; (8) laboratory services;(9) preventive and wellness services and chronic disease management; and (10) pediatric services, including oral and vision care.
For newly hired full-time employees who come on board after Jan. 1, coverage must be made available no longer than 90 days after hire.
Suggestion: State EHBs may vary, so make sure you know the requirements where you live.
4. Defining and counting your eligible full-time employees: The PPACA has redefined full-time employees for purposes of healthcare coverage. Now, employers must offer coverage to anyone who works an average of 30 hours a week. Calculating the 30 hours can be tricky, so you need to know the details. For instance, hours an employee is paid to work aren’t the only ones you count. You need to include the hours you pay someone not to work, such as vacation time, and hours of unpaid leave, such as jury duty. Having a good fix on who your eligible employees will be come Jan. 1 is critical to meeting the requirements of the law. To provide good data to the feds when they ask for it in 2015, employers will have to start tracking hours beginning this Oct. 1.
Suggestion: If you have put this exercise off because of the delay for sanctions until 2015, start counting now. You’ll need data from 10/1/13. Just because you don’t face sanctions doesn’t mean it isn’t essential to have a handle on this number.
5. 90-day waiting period: Under the PPACA, a group health plan or health insurance issuer offering group health insurance coverage must offer health coverage to new employees within 90 days of their hiring. No more “we’ll get you covered if you survive six months here.”
Suggestion: You might want to test potential hires out as contractors to make sure they’re a fit before you’re committed to coverage after 90 days.
6. Preventive services must be offered without cost-sharing: This requires group health plans to cover recommended preventive services without charging a deductible or co-pay/coinsurance. Grandfathered plans are generally excluded from complying with this provision. Among these services are immunization, well-woman visits, screening for gestational diabetes, screening for sexually transmitted diseases, well baby visits, and others.
Suggestion: If your benefits package includes a wellness program, you’ve got more assignments to complete before Oct.1. The idea behind these new rules is that all employees, regardless of their physical condition, should be able to meet the incentives built into wellness programs. Among the requirements:
7. Reasonable accommodations: Some employees, for various reasons, cannot meet the requirements established by wellness programs, so there must be options available for them built into the system.
8. The program must be designed to promote health or prevent disease: Wellness program goals must be tied to direct health benefits. Also, the goals established must not be “overly burdensome.”
9. Rewards must be available to all similarly situated employees: Again, because employees present a range of medical conditions, including some that may thwart them from achieving a reward, the conditions present in a given workplace have to be considered when designing the incentives and goals. Notice must be given to these employees of the options available to them.
Suggestion: Have a wellness program professional review your program to make sure that it is fair to all, truly promotes better health and includes incentives that any employee making a reasonable effort can hope to enjoy.