The following are a few of the Health Care Reform employer requirements for immediate consideration and action. These are only a few of the more significant provisions that employers should be considering if you have not already done so. Also, review our timeline of key provisions and dates that affect employers.
W-2 Reporting Requirements
Plan sponsors that were required to file 250 or more W-2 Forms during 2011 must report the cost of employer-sponsored health coverage on employee W-2 Forms beginning with the 2012 tax year, which are the W-2 Forms that are generally required to be provided by January 31, 2013. If you have not already done so, you will need to develop a plan for complying with the W-2 reporting requirements, perhaps in conjunction with your payroll administrator. Read more.
Health FSA Contribution Limits
Effective for plan years beginning on or after January 1, 2013, the amount an employee may contribute to a Health Flexible Spending Account is capped at $2,500 per year. If you currently allow employees to contribute more than that, you’ll need to determine when your plan will need to comply with the new contribution limit and amend your plan document, if necessary. Read more.
Summary of Benefits and Coverage Distribution
Plan sponsors or insurers must provide a Summary of Benefits and Coverage (SBC) to plan participants beginning with the first open enrollment period on or after September 23, 2012. You’ll need to complete the SBC template, or collect a completed SBC from your carrier if your plan is insured, and be prepared to provide a copy to participants upon request and during enrollments after September 23, 2012. Read more.
2014 Plan Design Mandates
For plan years beginning on or after January 1, 2014, plans will need to comply with several new plan design mandates, such as limits on waiting periods, deductibles, and out-of-pocket spending. Plan sponsors need to assess whether any of these changes will impact their plans and when to incorporate changes, if necessary. Read more.
Free Rider Penalty
Also effective Jan. 1, 2014, employers with 50 or more full-time equivalent employees that do not offer health coverage to full-time employees and their dependents, or offer coverage that is “unaffordable” or “inadequate”, and have at least one employee enroll in Exchange coverage and qualify for a federal premium tax credit, must pay a Free Rider Penalty. Employers will want to consider whether their current coverage is adequate and affordable, and to confirm whether their current eligibility rules will trigger a penalty. Read more.