The next three months are crunch time. Employers have to get moving on several deadlines, most of them required under health care reform. Some reform rules should have taken effect in 2014, but were subject to the year-long delay instituted by the Obama administration.
Health Plan Identifiers
Nov. 5, 2014 is the deadline for large group health plans to obtain a new 10-digit health plan identifier. Health plans must use HPIDs in certain electronic transactions by Nov. 7, 2016, and require their business associates to do the same.
Small health plans, meaning those with annual receipts of $5 million or less, have an additional year — until Nov. 5, 2015 — to get their HPID.
The insurer will obtain the HPID for fully insured plans, whereas self-insured plans must obtain their own HPID. The Centers for Medicare and Medicaid Services has created training materials to help with the application process. HPID FAQs are posted on the CMS website.
The definition of excepted benefit is narrower in the HPID rules than it is in health reform, and that means that HPIDs will have to be obtained for specific disease policies, and stand-alone vision and dental plans. Employers and insurers will have to get HPIDs for a larger set of plans and policies than are affected by market reforms under the Affordable Care Act.
Transitional Reinsurance Fee
Nov. 15, 2014 is the deadline for submitting information and scheduling payments for health care reform’s transitional reinsurance fee. The payments are not due on Nov. 15, but employers must upload their information by that date.
In accord with that deadline, CMS published a 64-page manual to help insurers, third-party administrators and employers to fill out their submissions. CMS told the public that submission forms will be available on www.pay.gov.
The fee is $63 per member per year, and it drops to $44 per member per year for 2015. Employers may split the transitional reinsurance fee into two parts: they may submit an initial payment of $52.50 per covered life by Jan. 15, 2015 and a second payment of $10.50 per covered life by Nov. 15, 2015. They may also pay the entire $63.00 per covered life on or before Jan. 15, 2015. The TR payment for 2015 becomes $44; insurers and plans can make an initial payment of $33 in and subsequent payment of $11.
Data Collection for the Employer Mandate
Jan. 1, 2015 is the start date for collecting data on employees and group health plans. Section 6055 reporting requires all employers to file the list of names of employees who are actually enrolled in minimum essential coverage provided by the company (to help the IRS enforce health care reform’s individual mandate). If the employer is fully insured, the insurer — not the employer — will file these reports.
Section 6056 reporting requires “applicable large employers,” with 100 or more employees to attest that the health coverage they offer meets minimum value rules, and to list the employees to whom an offer of coverage has been made, whether or not they actually are enrolled in plans.
Jan. 1, 2016. On this date, midsize employers with 50-99 employees will need to comply with the full scope ACA’s employer mandate, especially the penalties for non-coverage and inadequate or unaffordable coverage. (They are still required to file Section 6055/56 returns so they must collect data starting on Jan. 1, 2015. However, there will be no penalties for inaccurate reporting, if the companies make good faith efforts to comply.)
Midsize employers got an extra year to comply with the employer mandate from the Obama administration in February 2014. Some large companies with midsized competitors said they are being put at a competitive disadvantage in relation to those competitors who will not have to pay for health benefits for an extra year, Jeffrey Endick, a principal with Slevin & Hart, said recently.
On Feb. 1, 2016 statements of coverage will have to go to employees so they can file them with their tax returns. And on March 1, 2016 both reports are due to the IRS from employers that file on paper; and on March 31, 2016 for electronic filers. Electronic filing is required if an employer files 250 or more Section 6056 returns.
Employers want to look at the rules and requirements now if they want to make sure they can capture the data they need.
Other Dates
Oct. 1, 2015: ICD-10 code requirements are effective.
Jan. 1, 2017: Large employers will be able to purchase coverage from state-based health insurance exchanges mandated by health care reform. Currently, only companies with fewer than 100 employees are eligible. This will represent a new option for large companies.
Jan. 1, 2018: The high cost (“Cadillac” plan) excise tax, mandated under health care reform, will take effect.