BHCG Monitor: Focus on Health Care Benefits

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BHCG Monitor: Focus on Health Care Benefits - Health Insurance Exchanges


Health Care Reform – Notable News

ACA Reminders for 2015

In 2015 the Affordable Care Act‘s (ACA) employer “pay or play” mandate and additional reporting requirements under Sections 6055 and 6056 went into effect. Employers have spent the last year preparing for those top of mind requirements and the looming 2016 employer “Cadillac tax” on generous health plans. However, legal advisors and the federal government are reminding employers about the following items to be aware of throughout 2015.

Sections 6055 and 6056 reporting

Employers with 50-plus full-time employees must file a series of tax returns under the Internal Revenue Code sections 6055 and 6056. The returns must include whether each employee worked or was credited with enough hours to be deemed “full-time” during each month of 2015. If employers use the look-back method for determining full-time status, they should have already started counting employee hours in the last 18 months or so.

The IRA has issued a draft IRS form 1095c to report employee and employer health coverage information under Sections 6055 and 6056. It is a single, combined draft form that self-funded employers may use and includes instructions. For more information about reporting and disclosure requirements introduced by the ACA, see the Welfare Benefit Plan Reporting & Disclosure Calendar, courtesy of Quarles & Brady.

“Pay or play“– smaller employers

Smaller employers that are near the 50-employee threshold (to be considered an “applicable large employer”) need to pay attention to employee hours during each month of 2015. The monthly average of full-time employees and equivalents in 2015 will determine whether the employer is subject to the “pay or play mandate” in 2016. It is also worth noting that even small employers are subject to medical coverage restrictions that trigger the ACA’s excise tax penalty.

Transitional reinsurance fee

Self-funded employers should have already paid the first installment of the transitional reinsurance fee to the Department of Health and Human Services (DHHS) in January of this year. The second installment of the fee ($10.50 per covered life) is due in the fourth quarter of 2015.

Patient-Centered Outcomes Research Institute (PCOR) fee

The PCOR fee must be paid by self-funded plans by July 31, 2015 for the plan year ending in 2014. For plan years ending before October 1, 2014, the PCOR fee is $2.00 per covered life. For plan years ending after October 1, 2014, the PCOR fee is $2.08 per covered life. Keep in mind the PCOR is scheduled to go up in future years.

Summary of Benefit and Coverage (SBC)

Late last year, the federal government proposed changes to the ACA regulations regarding the summary of benefits and coverage (SBC) and uniform glossary for group health plans and health insurance coverage. These changes include revisions to the template documents, instruction guides, the uniform glossary and other supporting materials. If finalized, the proposed rules would make these documents more user-friendly and shorter and affect the requirements for SBCs and glossaries available for consumers for coverage on or after September 1, 2015.

‘Minimum value” standard

The IRS has issued guidance that health plans that do not provide coverage for in-patient hospitalization services or physician services will not meet the ACA’s “minimum value” standard. The IRS is intending to propose and finalize regulations to this effect in 2015.


Department of Health and Human Services. Department of Labor. December 2014. (accessed 2015).

Hinkle Law Firm. Employee Benefits Alert. January 2015. (accessed 2015).

Internal Revenue Service. American Benefits Council. 2015. (accessed 2015).

Stephen Miller, CEBS. "HR Topics & Strategy." Society for Human Resource Management. February 2015. (accessed 2015).

The Alliance. Health Policy. March 2015. (accessed March 2015).


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BHCG Monitor: Focus on Health Care Benefits - April 2012