Monday, May 27, 2013

ObamaTax Compliance heads' up

Received a sample notice that will (when finalized) have to be sent from employers to their employees later this summer. If you're interested, click here to download it. It's 3 pages, and pretty scary.

Scary, Henry?

Well, here's the thing. The employer will need to complete this form, and attest that, for example, his group plan meets the "minimum value standard." That is, that "the plan's share of the total allowed benefit costs covered by the plan is no less than 60 percent of such costs."

One presumes that the carrier will notify employers whether their group does, in fact, meet that criteria, but it's not entirely clear that this will be so for all carriers in all markets.

There's a related issue that so far seems to be flying under the radar: Exchanges and participation requirements. All carriers require that a minimum percentage of eligible employees sign up for coverage. This is to help reduce the chance of adverse selection, where only the least healthy enroll. The term "eligible" is somewhat flexible, but in general it's full-time employees who don't have "valid waivers." A valid waiver might be, for example, coverage through a spouse, or Medicare. Oddly, an individual medical plan does not qualify as a valid waiver, so that employee must be accounted for in the grand total.

So here's a question: if an employee opts off the group plan in favor of a (subsidized) individual plan from his state's Exchange, is that a "valid waiver?" This matters - a lot - because if enough folks opt off the group plan, it's going to go away, whether or not this is what the employer (and the other employees) want.

But remember: if you like your current plan, you can keep your current plan.

Or not.

[Hat Tip: FoIB Beth D]
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