Fall open enrollment for the 2015 group health plan year is being dominated by employer frustration and uncertainty about implementing coverage and IRS reporting requirements under the health care reform law’s employer coverage mandate.
“Open enrollment is going to present employers with some huge challenges this year,” said Steven Friedman, shareholder and employee benefits practice group co-chair at Littler Mendelson P.C. in New York. “There are quite a few hidden traps in the reform law’s mandate that could ensnare employers.”
The mandate requires employers with 50 or more employees to offer health care benefits to 70% of their full-time workers — defined as any employee who works an average of 30 or more hours a week — beginning in January, and 95% of full-time workers in 2016.
Experts say much of benefit managers’ concern has been focused on the Patient Protection and Affordable Care Act’s rules requiring most employers to certify that benefits-eligible employees and their dependents have been offered minimum essential coverage, and that employees’ premium contributions fall within cost-sharing limits established under the law.
“The reporting requirements under ACA are probably the No. 1 issue that we’re dealing with right now,” said Adam Solander, a Washington-based associate at Epstein Becker & Green P.C.
Starting in January, employers will need to track benefits eligibility of their full-time employees and submit annual reports to the IRS to document their group plans’ compliance with the law. The first reports are due in early 2016 for employers with at least 100 employees.
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Jeffrey R. Ungvary President