Healthcare Reform Update - December 9, 2015

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Reporting Examples on Form 1095-C

The Patient Protection and Affordable Care Act (“PPACA”) added Sections 6055 and 6056 to the Internal Revenue Code. Under these provisions, employers and other sponsors of minimum essential coverage (“MEC”) must comply with certain reporting and disclosure requirements beginning in 2016 for coverage provided during the 2015 calendar year. In September 2015, the IRS issued final 2015 Forms 1094-B, 1095-B, 1094-C, and 1095-C, as well as, final Instructions for use with those Forms. To assist employers as they strive to understand the nuances of the reporting and disclosure requirements, we have created some examples with very specific fact patterns as noted below.
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Sample Employee FAQs on Forms 1095-B and 1095-C

Many employers are facing numerous challenges as a result of the ever-changing regulatory landscape ushered in by PPACA. One of the new requirements that many employers are confronted with is meeting the reporting obligations under Sections 6055 and 6056 of PPACA, using both Forms 1095-B and 1095-C. To assist employers and their employees with the numerous nuances, we have developed two sets of sample employee frequently asked questions - one for self-insured health plans and one for fully insured health plans - that employers may wish to consider when communicating various components of their reporting obligations to their employees.
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Fully Insured Health Plans >>

Range of Issues Addressed in Proposed 2017 Notice of Benefit and Payment Parameters

On November 20, the Department of Health and Human Services (“HHS”) released the proposed 2017 Notice of Benefit and Payment Parameters. The rules address an assortment of issues under the Patient Protection and Affordable Care Act (“PPACA”) including risk adjustments, reinsurance, and risk corridors programs, cost sharing parameters, fees for the Federally-Facilitated Marketplaces, open enrollment for the 2017 Marketplace, the definition of a small employer, and guaranteed availability and renewability. The proposed Benefit and Payment Parameters rules are released annually in the fall and usually finalized the following spring. A bulk of the voluminous rules are applicable to insurers only, however, in this article we will discuss issues relevant to employers.
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Government Agencies Finally Finalize Regulations on PPACA Mandates
In November, the Departments of Labor, Health and Human Services, and Treasury (the “Departments”) released final regulations for several mandates that became effective shortly after the inception of PPACA. Specifically, the final regulations address what are commonly referred to as “market reforms,” including grandfathered plans, preexisting condition exclusions, lifetime and annual limits, rescissions, dependent coverage, appeals, and patient protections under PPACA. When PPACA was passed in March 2010, the Departments issued interim final regulations to implement the mandates six months later and have followed up since then with guidance as needed. There are no substantive changes to the interim final regulations, but the clarifications released over the years are now incorporated into the regulations themselves.
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Questions and Answers for Employers
Please click on the "Read More" link below to access our Healthcare Reform FAQs.
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