Thursday, September 24, 2015

Compliance Update

LifeCare Links - Cobble Hill Health Center

With summer behind us, and 2016 fast approaching, we’d like to remind our clients of recent regulations which were passed on both the state and federal levels which are worthy of notice.
NYC Transit Ordinance

SubwayNYC Transit Ordinance, Local Law 53, requires New York City employers with 20 or more full time employees, located within the 5 boroughs, to offer employees the opportunity to redirect up to $130 a month of their pretax paytowards transit benefits.  The law defines ‘full time’ as employees who work 30 or more hours per week, and exempts employees subject to a collective bargaining agreement.  The law takes effect on January 1, 2016, and allows employers a six-month grace period to comply. This mandate applies to employers who have locations with 20 or more full time employees in one of the five boroughs of New York City, and includes all employees regardless of their residence.  Penalties for non-compliance will range from $100 to $250 per month.
6055 & 6056 Filing Requirements - Update

Last November, we notified clients of the IRS Code 6055 and 6056 filing requirements. As a reminder, employers with 50 or more full time or full time equivalent employees are required to complete forms 1094 and 1095. Self insured plan sponsors are required to provide all employees who worked 30 or more hours per week, and waived coverage, with a 1095B, and employees who have been covered during any portion of 2015 with a 1095C by January 31, 2016. The 1094 and 1095 forms must be submitted to the IRS by February 28, 2016 if filed by paper, or by March 31, 2016 if filed electronically. Electronic transmittal is required for employers filing at least 250 forms. Penalties for non-compliance will be assessed at $250 per violation. The IRS released final forms and instructions on September 17, 2015. Although there have been several changes recently, they are minimal.

› Instructions for Form 1094-C and 1095-C
› Form 1095-C to both the IRS and individuals
› Instructions for Forms 1094-B and 1095-B
› Form 1094-B (a transmittal /cover sheet) to the IRS
› Form 1095-B to both the IRS and individuals
We know that this is a significant undertaking, and are ready to assist with information-gathering necessary to complete the documents. Reports intended to capture missing dependent social security numbers will be sent to all human resources personnel by their Friedman Associates account manager. The information will be used to provide our clients with the data necessary to complete Part III of Form 1095C.
Out of Pocket Maximum – New Regulation Regarding Individual Assessment of Out of Pocket

Non-grandfathered plans are required to include an in network maximum out of pocket, which reflect the maximum cost share a covered individual may be responsible for in a given plan year, and should include the plan’s deductible, coinsurance, and all copayments. In 2016, this amount will increase to $6,850 per individual, and $13,700 for family coverage. We expect the out of pocket to increase annually, however, clarification regarding family out of pocket assessment is recent. Notably, the regulation now applies the individual out of pocket to each member of a family unit, and requires plans to pay 100% of covered expenses once an individual, whether enrolled in a single or family unit, has met the individual out of pocket. Additionally, once a family’s out of pocket has been met, all covered expenses must be paid in full, regardless of whether or not all of the individuals of the family unit have met their maximum out of pocket.
Preventive Care Benefits Expanded

 Non-grandfathered plans are required to include benefits for all:
  • Evidence based items or services that have in effect a rating of ‘A’ or ‘B’ in the current recommendations of the USPSTF for preventive purposes.
  • Routine immunizations for children and adults as recommended by the ACIP of the Centers for Disease Control and Prevention
  • Childhood and adolescent screening and preventive services recommended by the Health Resources and Services Administration
  • Preventive care and screening for women, as advised by the Health Resources and Services Administration
Included in the expanded preventive care guidelines is a requirement to cover all forms of contraception, including sterilization, BRCA testing, and dependent prenatal care. These services must be implemented upon a plan’s renewal on or after August 1, 2015.
 › Read the FAQ released by the DOL
Transitional Reinsurance Fee

The Transitional Reinsurance Fee is assessed annually, and paid by all health plans, whether insured or self-funded. The fee for 2015 plan years is $44 per covered person, and is due by January 15, 2016. Plans have an option to pay the fee in installments, with the first installment of $33 due by January 15, 2016, and the balance payable by November 15, 2016. This fee is paid through accessing ‘ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form’ on Look out for our reminder email with membership counts in mid-November.

Feel free to contact your Account Administrator with any questions.

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