A number of delays have plagued the implementation of the Affordable Care Act, and new deadlines have been established. Following is a brief rundown of delays and deadlines to keep your understanding of the ACA up to date.
Reporting employee status: Employers must begin to collect information about their employees’ status over a 12-month period of their choosing in order to estimate their tax liability when the employer mandate takes effect next year (see Delays, below). Beginning in 2015, employers subject to the mandate will be required to offer coverage to employees who work full-time or pay the corresponding penalty.
Marketplace notification: Employers subject to the FLSA should have notified their employees of available health care options on the health insurance exchanges by October 1, the enrollment start date. If you haven’t yet notified your employees, do so ASAP.
Summary of Benefits: Employees must receive a summary of their provided benefits no later than 30 days before the beginning of the plan year. The summary must indicate whether coverage meets the minimum essential standard established by the ACA.
Small Business Health Options Program (SHOP) marketplaces: Originally slated to roll out with the individual marketplaces on October 1, the federal government delayed the launch of the SHOP marketplaces to November 1. Plans purchased on the exchange will still begin January 1, and small businesses that purchase their plans through brokers or other means will not be affected.
In addition, the marketplaces will have an additional year to offer a la carte plan options, in which businesses may choose individual coverage for their employees within an overall package.
Employer Mandate: Companies employing more than 50 full-time employees now have until 2015 to provide minimum essential coverage before they are subject to the $2,000-$3,000 per employee tax penalty for noncompliance.
Out-of-Pocket Limits: Some insurance plans will not be subject to consumer out-of-pocket limits ($6,350 for an individual/$12,700 for a family) until 2015. During the delay period, employers who offer separate plans for care and pharmacy benefits will be allowed to maintain separate limits for each plan, and plans that do not have a limit will not be required to implement one.
Update on the Individual Marketplaces
Technological issues that crippled several state exchanges soon after their launch have been resolved, leading to tens of thousands of new enrollments during the first week of operations nationwide. In the meantime, federal officials have acknowledged the need for design and server updates to the federal exchange at healthcare.gov to handle the high levels of traffic and make the experience more user-friendly.