AFFORDABLE CARE ACT (ACA) – IN CASE YOU MISSED IT – UPDATES FROM MARCH & APRIL
March and April were busy months for changes to health care reform. As promised, we’re keeping you abreast of the relavent updates in the Affordable Care Act. Here are the highlights we found pertinent to you all!
March
March 5-The Department of Health and Human Services (HHS) published rules establishing the cost-sharing limits for health plans for 2015. The annual deductible for a health plan in the small group market for 2015 may not exceed $2,050 for self-only coverage and $4,100 for family coverage. The out-of-pocket maximum cannot exceed $6,600 for self-only coverage and $13,200 for family coverage. The full account of Benefit and Payment Parameters are found here.
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The same day (March 5) the IRS finalized rules pertaining to the ACA information reporting requirements (Sections 6055 and 6056). Section 6055 requires health insurance issuers, self-insured health plan sponsors, government agencies that administer government-sponsored health insurance programs and any other entity that provides minimum essential coverage to report information on that coverage to the IRS and covered individuals. Read more here.
Section 6056 requires employers with at least 50 full-time employees to report to the IRS and to covered individuals information on the health coverage offered to full-time employees. More information can be found at the Federal Register.
The final regulations apply for calendar years beginning after Dec. 31, 2014.
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Also released on March 5, HHS released an Insurance Standards Bulletin that extends a transition relief policy for canceled health plans for two additional years (which applies for policy years beginning on or before 10/1/16). Health insurance issuers have the option of renewing policies for current enrollees without adopting all of ACA’s reforms if permitted by their State. This may result in individuals and small businesses being able to keep their non-ACA compliance coverage into 2017 (depending on the plan or policy year).
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On March 14, HHS issued an FAQ regarding how ACA’s guaranteed availability requirements affect health-insurance for same-sex spouses—clarifying that the mandate prohibits discrimination based on sexual orientation.
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On March 28, the IRS released guidance regarding the flexible spending account (FSA) carryovers and health savings account (HSA) eligibility. In short, an individual carrying over unused FSA funds from a prior year to a current year will not be eligible for HSA contributions for the entire current plan year.
April
On April 1, provisions were signed into law to eliminate the ACA annual deductible limit for health plans in the small group market (to be retroactively effective to when the ACA was enacted in March 2010). The outcome would allow small employers to select a health plan with a higher deductible (as a way to control premium costs).
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On April 21, the Department of Health and Human Services (HHS) issued some Frequently Asked Questions to provide guidance for situations where a COBRA qualified beneficiary may enroll in a qualified health plan through an Exchange and receive subsidies. The FAQs clarified that individuals can voluntarily drop COBRA coverage and enroll in a qualified health plan (and possibly qualify for a subsidy) during the Exchange’s open enrollment period (or when COBRA coverage expires).
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On April 23, the IRS announced the 2015 limits for health savings accounts (HSAs). The annual limit for self-only coverage under a high deductible health plan (HDHP) will be $3,340 and the family contribution limit will be $6,650. The maximum out-of-pocket expense limit for self-only HDHP will be $6,450, and family coverage will be $12,900. The deductibles under a HDHP must be at least $1,300 for self-only and $2,600 for family coverage for 2015.
