Comparative Effectiveness Research Fee (CERF)
Today’s update focuses on the Comparative Effectiveness Research Fee (CERF) mandated by the Patient Protection and Affordable Care Act (PPACA). The annual fee will be due for plan years ending after October 1, 2012. The annual fee for 2012 will be $1 per covered life including retirees and dependents. (For example, if your plan covers 200 employees plus 150 dependents and retirees the fee for 2012 will be $350 for the 2012 plan year.)
Summary of Benefits and Coverage and Notice of Material Modifications
Today’s update focuses on the final regulations for Summary of Benefits and Coverage and Notice of Material Modifications required under health care reform. The final regulations were issued in February 2012 followed by a FAQ in March 2012.
Reporting Cost of Health Care Coverage on W-2 Forms
Today’s update addresses the requirement for reporting employee health insurance costs or premiums on W-2 Forms. The IRS issued a notice in January further defining this requirement. Attached is a brief overview of the requirements. /sites/default/files/blog-content/u6/W-2%20Compliance%20Instruction%20-%20March%202012.pdf Please note, this document varies significantly from the one issued by our office in November 2011.
Health Care Reform
Today’s compliance update will focus on planning for health care reform for 2012 and beyond. The next 12 to 18 months will be important for understanding changes happening this year, but more importantly planning for changes scheduled to be implemented in 2014. Please see the attached document for more details, but here is a highlight of some of the items to consider. /sites/default/files/blog-content/u6/Health%20Care%20Reform%202012-2014.pdf
Summary of Benefits and Changes
The Department of Labor issued an FAQ on 11/17/11 which provided guidance that employers and administrators are not required to comply with the Summary of Benefits and Changes (SBC) until the final regulations are issued. The FAQ also states “It is anticipated that the Department’s final regulations, once issued, will include an applicability date that fives groups health plans and health insurance issuers sufficient time to comply". See the FAQ at http://www.dol.gov/ebsa/faqs/faq-aca7.html
W-2 Forms
Beginning in 2012 (with the reporting beginning in January 2013), employers who file more than 250 W-2 Forms are required to report the cost of employee health insurance on W-2 forms. Employer who file fewer than 250 W-2 Forms will not be required to report until further guidance is provided. See the attached document which provides an overview of the requirements.
Patient Protection and Affordable Care Act
The Patient Protection and Affordable Care Act (PPACA) includes a requirement for Plan Administrators to create and distribute a Four-Page Summary of Benefits and Changes document and to provide Notice of Material Modifications. Interim regulations were issued in August 2011 for this requirement, which is scheduled to go into effect on March 23, 2012. While the Summary of Benefits and Changes (SBCs) will not need to be issued to existing employees until your group health plan renews, new employees will need to receive the SBC when they become eligible for coverage.
CHIPRA Notice Requirements
CHIPRA, or the Children’s Health Insurance Program Reauthorization Act of 2009, was enacted on February 4, 2009. Under CHIPRA, states may provide premium assistance subsidies toward qualified employer-sponsored health insurance coverage, rather than enrolling the individual in CHIP (Children’s Health Insurance Program), Medicaid or MaineCare. This premium assistance may be provided when it is cost-effective for the states to do so, as long as the plan qualifies as creditable coverage under HIPAA, the plan satisfies certain nondiscrimination rules, and the employer co
