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Monday, 21 November 2016 15:13

1095 Reporting Changes and Delays

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Not long after indicating that there would be no exceptions to the January 31st deadline for 1095 B & C forms, the federal government reversed itself. You may have heard there are several delays and changes that have been announced for this year’s reporting:

If your company administers a self-funded medical plan, you need to be aware of benefit changes that should be made in 2017 to comply with Section 1557 of the Affordable Care Act. Section 1557 prohibits discrimination on the basis of sex, age, race, color, national origin, and disability. 
 
The regulations were released by the Department of Health and Human Services (HHS), and specific requirements were laid out for health insurance coverage for transgender individuals. 

Employers that offer partially self-funded medical plans are subject to the Transitional Reinsurance fee established by the Patient Protection and Affordable Care Act (PPACA). 

This fee was imposed over a three year period, with 2016 being the third and final year. The fee in 2016 is $27 per average covered life (both employees and dependents) covered on the health plan in 2016.  

Partially self-funded plans need to take action soon by reporting their average number of covered lives for the first 9 months of 2016 to The Department of Health and Human Services (HHS) by the deadline of November 15th, 2016.

The annual Kaiser Family Foundation/Health Research & Education Trust Employer Survey is always a great source of information about the trends in employer-sponsored health coverage.  This year’s big conclusion is that while final premium increases were not that high, the average was markedly reduced by even more movement to cost-saving High Deductible Health Plans (HDHPs), which means employees likely have less rich benefits than before.

On January 1, 2017, new wellness program rules from the Equal Employment Opportunity Commission (EEOC) go into effect. These rules differ a bit from those under HIPAA and the ACA, so we recommend every employer review and revise their wellness program to ensure compliance, including new rules around incentives, new limitations on the types of info gathered in Health Risk Assessments on family members, and newly required notices you must provide to employees.

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