What's Happening With Health Care Reform?

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B. Michael Haffey CLU, Member Benefits Inc.

Now that Jan. 1 has come and gone, what should individuals and employer groups know about the new health care reform law?

First, for individuals, is the mandate or shared-responsibility requirement that almost all U.S. citizens are to be covered by an insurance plan that provides minimum essential coverage by April 1 or the IRS will collect a tax penalty for not being insured. Be careful – the new law controls the ability to consume health insurance during 2014 with an open-enrollment period that ends March 31, 2014. Outside the open-enrollment period, you can enroll in a private insurance plan only if certain life events give you a special enrollment period. They are:

  • Getting married
  • Having, adopting or placement of a child
  • Permanently moving to a new area that offers different health-plan options
  • Losing other health coverage (for example because of job loss; divorce; loss of eligibility for Medicaid or CHIP; expiration of COBRA coverage; or a health plan being decertified). Note: Voluntarily quitting other health coverage or being terminated for not paying your premiums is not considered loss of coverage. Losing coverage that is not minimum essential coverage also is not considered loss of coverage.
  • For people already enrolled in coverage, a change in income or household status that affects eligibility for tax credits or cost-sharing reductions

If you don't have health insurance today and you don't anticipate one of these events, it would behoove you to be covered before the end of March. Otherwise, you’ll likely need to wait until next fall, when the open enrollment period runs from Nov.15, 2014 through Jan.15, 2015.

All employer groups, whether or not they offer group health insurance, must comply with a new requirement to distribute the ACA required exchange notice to their employees. Regardless of their size, those that offer a group health-insurance plan must comply with the requirements of the new law effective on the anniversary date of their health plan starting on or after Jan. 1, 2014.

Many small employers erroneously believe the new ACA compliance standards don’t apply to them because they have fewer than 50 employees. The administration also delayed the employer mandate (Play or Pay) by pushing back the requirements to Jan. 1, 2015 for groups with 50 or more employees. Because of the delay, employers may believe the other compliance requirements of the law also have been delayed. This is not true. Employer groups of all sizes need to take necessary steps to comply with the law now during 2014.

Another issue employers are dealing with is that by offering a group insurance plan that is affordable (based on the new math) and meets the new minimum-value requirement, employees – regardless of their income – are disqualified to receive government subsidy money for which they otherwise may qualify. This money is available to help reduce the real cost of their insurance. However, they can’t take advantage of it because their employer offers a group health plan.

For this and other reasons, many employers are evaluating the decision to drop their group coverage and move employees to individual policies that now are available on a guaranteed-acceptance basis and without pre-existing condition limitations. An employer can make this decision at any time during the year because it opens a special enrollment period for employees to purchase minimal essential coverage through an individual plan. Individual health policies can be purchased either through a private exchange, such as the FICPA-endorsed CPA Insurance Marketplace (off-exchange plans), or through healthcare.gov (on-exchange plans) where government subsidies may be available for those who qualify.

If you have questions or want to explore your new options under reform, contact Member Benefits at (800) 282-8626 or visit http://www.memberbenefits.com/ficpa.

B. Michael Haffey, CLU is director of business development at Member Benefits Inc., the administrator of the FICPA-endorsed CPA Insurance Marketplace. You may contact him at (800) 282-8626 or mhaffey@memberbenefits.com.

More information: B. Michael Haffey, CLU, Member Benefits Inc. | (800) 282-8626 | mhaffey@memberbenefits.com | www.memberbenefits.com/ficpa