Healthcare Reform Update - February 14, 2018
HHS Releases Final 2019 Actuarial Value Calculator
The Department of Health and Human Services (“HHS”) recently released the final 2019 Actuarial Value (“AV”) Calculator and AV Calculator Methodology. The AV Calculator is required to be used by issuers of non-grandfathered health insurance plans offered in the small group and individual markets, sold both through and outside of the Marketplace and to determine the level of coverage - bronze, silver, gold, or platinum. Changes have been made to the 2019 AV Calculator and Methodology when compared to the 2018 version. The 2019 AV Calculator and Methodology are only applicable for 2019 plans and do not affect 2018 or earlier plans.
Reporting Reminder: Extended Deadline to Furnish Forms 1095-B and 1095-C to Individuals and Return of Good Faith Relief
Late last year, the IRS extended the deadline to furnish Forms 1095-B and 1095-C to individuals to March 2, 2018 and has provided relief from penalties for filing or furnishing incorrect or incomplete statements to entities who can show they have made a “good faith” effort to comply. We have updated our Sections 6055 and 6056 Reporting Requirements Toolkit to reflect these changes, as well as for recent changes for the 2017 reporting year – which will prove valuable for employers as they work towards compliance.
PPACA Effective Date Watch List 2018-2022
PPACA was enacted on March 23, 2010, but its provisions become effective within a range that spans from 2010 to 2022. The charts below provide a quick list of provisions that either begin or will significantly change in 2018 through 2022. A list of provisions for which the effective date has been delayed or is unclear, along with a list of requirements that will apply to plans losing grandfathered status, follows the charts.
De Minimis Error Safe Harbor for Form 1095-C
The final 2017 Instructions for Form 1095-C contain important guidance on the requirement to file corrected Forms with the IRS and provide corrected statements to employees when there are errors in original filings. Generally, when errors are discovered, a corrected Form should be filed and distributed as soon as possible. Employers that fail to provide corrected statements to responsible individuals may be subject to indexed penalties (although “good faith” reporting has been reinstated for the 2017 reporting year). Regardless of good faith reporting, employers now have the “de minimis” error safe harbor to provide potential relief for errors of a small amount.
Questions and Answers for Employers
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