Employer Pay or Play Penalty Delay

January 1, 2015

Individual Mandate Penalty Still

April 1, 2014

New Delay Announced under the Affordable Care Act

Employers will have more time to

Offer or not offer health coverage

Select Insurance Plan(s)

Develop pricing and implementation strategy

Test to minimize possible future penalty under Pay or Play

No Delay for Employers

Health Plans must still meet all other requirements such as 90 day waiting periods and no pre-existing condition clauses

Notification requirements such as Summary Benefits Coverage (SBC) and Exchange Availability Notice

Honor System for Individuals

IRS won’t be able to determine if the employee has affordable and minimum value health care coverage

Indications are that individuals will also self-attest to income for 2014 to get subsidy and verification may be difficult

Lack of Reporting from Employer and Individual Self-Reporting May lead to some individuals getting a premium tax credit when they are not eligible

Impact to Individuals

Could lead to a tax liability when they file their taxes at the end of 2014 and/or disenrollment from the plan they have selected in 2015

Impact to Employers

State Exchanges may want to verify employer coverage directly instead of accepting individuals’ word

Employees will want to know what to do

Employees on exchange in 2014 could trigger $3,000 penalty in 2015 if they remain in the exchange.

What can an Employer do to reduce the confusion?

Communicate Now

Is our plan considered affordable?

It is, so you should answer yes to the question on employer coverage

Consider Using Exchange Notice Due on October 1, 2014

We will not offer health insurance in 2014

We will offer affordable and minimum value health insurance in 2014

To High-Light type of Health Insurance that will be available in 2014

The Best News for Employers is there will be more time to get it right without a penalty

If you found this information valuable, then please pass it on!

Thank you!

www.bclsystems.net