Health Care Reform: Three Upcoming Employer Deadlines

“Since 2010, when the Patient Protection & Affordable Care Act was passed, a gazillion news stories, articles and seminars have talked about what the act means and requires… One of the many issues that everyone has been talking about is whether employers should play or pay… If you are an employer who has decided to play, you need to be proactive now – not next month, not next year – to make sure you will, in fact, offer coverage to all of your full-time employees in 2014, when the penalty kicks in.” (McAfee & Taft)

Employers that sponsor group health plans need to stay in front of a broad range of new requirements and obligations under the Patient Protection and Affordable Care Act. Here are the three most pressing:

1. Distribution of Summary of Benefits & Coverage:

“Health plans must distribute a Summary of Benefits and Coverage (SBC) to all plan participants … and beneficiaries beginning on the first day of the first open enrollment period that begins on or after September 23, 2012 (the first day of the plan year beginning on or after September 23, 2012, for those participants and beneficiaries who do not enroll in coverage through an open enrollment period, including individuals who are newly eligible for coverage or who are eligible for special enrollment under the Internal Revenue Code).” (McDermott Will & Emery)

2. W-2 reporting of health care costs:

“W-2 forms for 2012 (to be issued in early 2013) must report the aggregate cost of applicable employer-sponsored group health plan coverage – this includes both employer and employee cost shares. Employers filing fewer than 250 W-2 forms for the preceding calendar year are currently exempt from this requirement. Ancillary benefits such as long-term care, HIPAA excepted benefits (i.e., certain dental and vision plans), disability and accident benefits, workers’ compensation, fixed indemnity insurance and coverage for a specific illness or disease are excluded from the value to be reported.” (McNees Wallace & Nurick)

3. New limits on Flexible Spending Accounts (FSAs):

“Beginning January 1, 2013 for calendar year plans and the first day of the plan year that begins after December 31, 2012 for non-calendar year plans, the maximum salary reduction contribution to a health flexible spending arrangement (FSA) is $2,500. Plan sponsors have until December 31, 2014 to amend their documents, but the FSA must be operated to reflect the limit beginning on the first day of the plan year.” (Poyner Spruill)

The updates:

Further reading:

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