Although there was a delay in the Play or Pay component of the ACA, employers still have many responsibilities in This is not intended to be an extensive review of the provisions - just some highlights. Every company should have a professional review the specific requirements needed. We have a GREAT resource. In fact, we provide a no obligation review if you would just like to have a second opinion.
Customize the attached Hi-Tech template to meet your organizational needs. As this is a legal document relating to employee training, please have counsel review.
- Make sure you have a HIPAA Hi-Tech policies and procedures manual
- Make sure you follow what your procedures say you will do. How soon do you train new employees on their obligations for protecting PHI?
- What method of training do you use. We provide this for clients through ThinkHR Training. The government also has resources http://www.hhs.gov/ocr/privacy/hipaa/understanding/training/index.html
- Are you using secure email when sending PHI via the cyber pathways? We have suggested vendors and added secure options. Even with some insurance companies I see work to be done. Costs have come down tremendously in the past few years. Options are plentiful. If you have few transactions, many of these are free.
- I use www.rpost.com. Click on the Secure Email link to go to their site. IT folks like it because it can be used entirely via website. No downloading software to interact with your server. However, it's much simpler to add a plug in to Outlook or many other popular forms of mail. Sending registered is next to the regular send button, which is a good reminder every time an electronic submission is ready to be distributed. If you use rpost.com, let me help you set it up. True to form, private information is not stored. However, you can set up the system to be notified when the recipient picks up the mail and also have a copy information sent to you. They have some free options, but I typically use much more than the allocation.
Note you must also provide this within 14 days to all NEW hires - Suggestion - amend your procedures manual for new hires and update your checklist to include the Marketplace Notice with the other information.
We provide your particular plan information ready so all you need to do is distribute the material. Please note Electronic Communication alternatives and the safe harbors that are inherent in electronic delivery. Many companies do not pass the safe harbor.
WHAT IS INCLUDED IN THE MODEL NOTICE AND HOW DO I FILL OUT THE PART ABOUT AFFORDABILITY AND MINIMUM VALUE?
Click on the link for Minimum Value for an explanation
You will see this question on the Model Marketplace Notice. However, this notice is not the only time you will need the required information. If you have employees who apply through a public exchange, you may need to complete an "Employer Tool" page. The government has tried to keep consistency, and the information required on the Employer Tool page is in the same order and format as the Model Exchange/ Marketplace notice. See Individual applications or the Marketplace for a sample. If you are a large employer (50+ equivalent full time employees) your calculations are created by the Minimum Value Calculator (below). I highly recommend having your agent complete this for you or assist you in the compilation.
For groups under 50 full time equivalent employees, the insurance company is required to provide information as to whether your plan is a BOTH a Qualified Health Plan (has essential minimum benefits and provides at least 60% value (the plan is expected to pay out at least 60%). Whether your plan is affordable is the same for large employers. If you offer more than one plan, any qualified plan can be used. If the single employee contributions is 9.5% of less of the employees annual wages, your plan is deemed affordable.
You can either send out a general annual notice and then give subsequent new hires a copy with their other information. Or you can customize notices with the information employees may need in order to enroll in a Medicare Part D prescription plan or a Medicare Advantage plan. If the prescription drug benefits in your plan do not provide at least the actuarial equivalent of Medicare's Part D coverage an employee could be penalized by paying 1% per month additional premium for every month they did not have creditable coverage prior to enrolling in Medicare's options. If they were on a non creditable group plan for 12 months prior to joining a Medicare option, that means they pay 12% more than the regular price for the coverage. PLEASE BE CAREFUL TO COMMUNICATE THIS IS YOU HAVE HIGHER DEDUCTIBLE OPTIONS THAT MAY NOT BE CONSIDERED CREDITABLE.
Most employers must submit to CMS (Centers for Medicare Services) a brief annual online reporting of your health insurance plan's prescription drug coverage creditability. It gives them a database to reference when one of your employees changes to Medicare. This should be done within 60 days of the end of the plan year you are reporting and within 30 days of any change in the status of your plan's RX creditabiity. For this particular goverment purpose, your annual plan year will be considered your renewal date (unlike Plan Years for other reporting purposes). If you report a calendar year Plan Year but your renewal is not until April, you report the information within 60 days of your renewal date. THE SITE FOR REPORTING IS https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/CCDisclosureForm.html
Think again if you believe you can just put the information on my benefit website and be considered in compliance?
Note- insurance companies typically include the required notices in the plan certificates / policies that are provided to employees. They also will provide the Summary Plan Description within the certificate in most cases. However, are they sending policies to employees that include these SPDs? They most likely are sending you electronic copies for either posting or copying. The responsibility is then the employers to make sure the documents are delivered in a timely fashion. THE KEY COMPLIANCE IS SHOWING YOUR PROCEDURAL GOVERNANCE IS TO PROVIDE EACH EMPLOYEE WITH THE REQUIRED INFORMATION.
As DOL audits increase, and regulations become more burdensome. We have a variety of solutions to help.
As DOL audits increase, and regulations become more burdensome. We have a variety of solutions to help.
Your insurance provider should supply the required Summary of Benefit Coverage in the proper format. hese must be provided at open enrollment, at time of eligibility / hire date, and during special enrollment qualifying events.
If you have multiple plans, you must provide copies of the SBCs for each plan offered. Is this a lot of paper? Absolutely. Can you simply provide these on an intra company website or an employee benefit website? For new hires there are some exceptions.
Corporate Insurance Advisors, Inc. does not intend to provide legal or financial advice.