8 reasons for employers to keep their PPACAguard up

Forget the delays for a minute. Here's what the national lawfirm Bryan Cave had to say about which PPACA provisions remain ineffect for employers in the year ahead.

1. Summaries of Benefits and Coverage must be distributed duringopen enrollment for the 2014 coverage period and must indicatewhether the plan provides minimum value, as defined underPPACA.
2. Exchange Notices: Employers must distribute PPACA exchangenotices to employees by Oct. 1, 2013, and thereafter to newemployees upon hire.
3. Application for Advance Premium Credits: Employers are requiredto complete a 12-page form, “Application for Health Coverage andHelp Paying Costs,” when requested by employees who are applyingfor PPACA advance premium tax credits when purchasing coverage viaan exchange.
4. PPACA fees: Patient-Centered Outcome Research Institute Fees(“PCORI Fees”) must be paid in July 2013 (that's now!). The firsttransitional reinsurance fee must be paid on or before Jan. 15,2015.
5. W-2 reporting: Employers must continue to report the aggregatevalue of health coverage on Forms W-2.
6. Counting Period for Employer Mandate: Employers that need todetermine whether they will be subject to the employer mandate in2015 (50 or more full-time or full-time equivalent employees in2014) will need to record employee hours in 2014. It's not yetclear whether a short counting period will be available, whichmeans that employers may be smartest to begin to track hours on aper-employee, monthly basis on Jan. 1.
7. Benefit Mandates For All Plans: Plan design requirements forall plans continue to apply (e.g., maximum 90-day waiting period,no limits on pre-existing conditions or essential health benefits,expansion of wellness incentives, dependent coverage to age26).
8. Benefit Mandates for Non-Grandfathered Plans Only: Plan designrequirements for non-grandfathered plans only continue to apply(e.g., preventive care coverage requirements, limits onout-of-pocket maximums, etc.)

—Dan Cook

A quiet week usually reserved for barbecues,family get-togethers and a day or two off from work turned morecomplicated than anyone expected when PPACA stalled out on the wayto full implementation. The Obama administration announced July 2it would delay the employer mandate penalty for one year.