As an employer, whether large or small, you’ve likely had to sift through vast amounts of healthcare reform regulation that impact your business. With fall now upon us, there are provisions for you to begin considering regardless of your company’s size.

Here is a checklist of what all employers need to think about while preparing for the Affordable Care Act (ACA):

Now Through Early Fall:

Marketplace notification to employees
If you have not already done so, the ACA requires you to notify your employees in writing, by October 1, 2013 that the Health Insurance Marketplace exists. Templates of this notice are available to download on the Department of Labor website. Employers must also notify new employees within 14 days of their hire. You can visit UnderstandingHealthReform.com for links to the website and templates.

January 2014 Regardless of Renewal Date:

Educate employees about Medicaid options
Based on household income, members of your workforce may be eligible for Medicaid. In these cases, you should provide them with information on determining eligibility and options.

Taxes and fees
Beginning January 1, 2014, five new taxes and fees will be added to the purchase of health benefits. These will be billed to employer-sponsored coverage and collected in January even on plans with non-calendar year renewal dates. See table below for a breakdown of fees by type of coverage.

Upon Renewal, January 2014 and Beyond:

New out-of-pocket maximum imposed

Upon renewal, all medical plans with the exception of those that are grandfathered must have an annual limitation on cost-sharing for covered services. This out-of-pocket maximum is designed to limit what the enrollee pays for deductibles, coinsurance or copayments for the policy year. Once the out-of-pocket maximum is met, the enrollee will stop paying copayments for all covered services, including prescription drugs, since this is a true out-of-pocket limit. Out-of-network services do not apply to this limit. Depending on plan design, this may increase premiums if other offsetting benefit changes are not made.

These limits are at the same level as the out-of-pocket maximums that are in place for high-deductible plans, and the amount is set annually. For 2014, these amounts are $6,350 for single coverage and $12,700 for family coverage.

Implement changes to waiting periods
Group health plans cannot impose a waiting period that is longer than 90 days from the start date when an employee becomes eligible to participate in a plan. Plans do not have to offer coverage to all groups of employees (part-time, etc.), but when coverage is offered the waiting period rule applies.

This provision begins for plan years beginning on or after January 1, 2014. While not effective for all groups January 1, the provision will eventually affect all groups as each one renews.

New rules for wellness programs
Also effective January 1, 2014 are new wellness requirements that will alter how rewards can be granted. They apply to both insured and self-funded group plans as well as those plans that are considered grandfathered by the ACA. Highlights of this provision include:
 

• An increase in the maximum allowable refund from 20% to 30% of the total cost of employee-only coverage. A maximum reward amount of up to 50% can be provided for programs whose primary objective is to “prevent or reduce tobacco use.”
• Clarification on the types of wellness programs, including classifying health contingent wellness programs as “activity-only” or “outcomes-based.”
• Relaxed qualification requirements will ensure that “similarly situated individuals” can earn the same reward by satisfying a reasonable alternative to the defined activity or outcome.

Beginning to Prepare for 2015:

As regulations are still being determined, one thing is for sure – being prepared will help you make the best decisions for your business and workforce.

To get more of your questions answered about health reform, visit Priority Health’s  UnderstandingHealthReform.com.

Marti Lolli is Senior Director of Product Development & Health Care Reform for ASE member firm Priority Health.