Peter Freska, CEBS
The LBL Group, A UBA Partner Firm
For the last couple of years we have been talking about Health Care Reform, but has anyone been listening?
First there was the debate of the legislation, then the “fix” legislation, then the elections, then the Supreme Court Ruling. There were a lot of “then there was”…And now, the question seems to be if anyone really understands the legislation. The alphabet soup of Federal organizations (HHS, DOL and IRS) are working diligently to get out the next interim final guidance – and if I hear somebody say “what we know today could change tomorrow” one more time…Well, you get the idea.
In fact, in the past week I attended a meeting with a large national insurance carrier who stated that they are still waiting for guidance on over 1,200 elements of health care reform. An April 2013 release from the Kaiser Family Foundation found that “Six Months Before Open Enrollment Begins, Many Americans Remain Unaware Of, Or Confused About, The ACA.” To make it even more interesting, the Kaiser Family Foundation surveys also reported that “four in ten Americans [were] unaware that the ACA is still law of the land and is being implemented.”
So, with so many pending items and lack of awareness, what should employers do? Here is a list of items employers should already be engaged in with their Advisers (adapted from UBA Partner Firm Presentations):
Step 1: Understand General Pay or Play Rule.
Step 2: Determine if You are a “Large Employer.”
Step 3: Will any of your employees receive federally-subsidized exchange coverage?
Step 4: Verify whether you offer “Minimum Essential Coverage” under an employer plan.
Step 5: Ensure that your plan provides “Minimum Value.”
Step 6: Verify the coverage is “Affordable” for Employee.
Step 7: Determine How Penalty is Calculated.
Step 8: Review Strategic Considerations with your Adviser.
The Next, Next Steps…With all of this settled and understood, employers need to turn to the policies and procedures that will allow them to manage the implementation of health care reform. And, we cannot forget about the impending “Cadillac Tax” for 2018. What is your company doing to mitigate its exposure to this rule?