Larger Employer Mandate Delayed Until 2015-What Does This Mean?

As many of you know, the Department of Treasury announced that the Employer Mandate for large employers (employers with more than 50 full time equivalent employees) is now delayed until 2015. Employers that currently do not offer coverage will now be relieved of offering coverage or facing a $2,000 per employee fine for another year. In addition, employers will not be subject to the $3,000 per employee fine for employees participating in the healthcare exchange(s), also known as the “marketplace”.

For many groups that currently offer coverage, this also delays many provisions of the employer mandate or “pay or play rules”. It is our understanding that premiums will not have to meet the “affordability requirements” based on household or individual box 1 income (since there is no longer a fine involved). Plan conformity to the 60% actuarial value, offering to all full time employees regardless of job title, and other provisions will likely be postponed.

We will continue to research the new rules and regulations as they develop. Based on the most recent decision, it’s difficult to know what the Government may change or delay next. We will do our best to update everyone as new information is released. Unless there is another delay, we still expect all employer groups will have to distribute the Department of Labor notice on the healthcare exchange by October 1, 2013. If the exchanges are still made available and not delayed, we will be happy to help your employees with their questions. The delay has definitely created more questions than answers. The bottom line for all employers with more than 50 full time equivalent employees is this: whether you offer healthcare coverage or not in 2014, you will not have to pay a fine or tax.

Some mandates that are “likely” to still be required when you renew your plan in 2014:

1) Waiting periods cannot exceed 90 days from the date an employee becomes eligible.

2) All pre-existing conditions for new hires or new additions to your plan will be eliminated.

3) The out of pocket maximum on your plan may not exceed $6,350 for an individual or $12,700 for family coverage.

4) Essential Health Benefits may not have annual dollar maximums.

5) Dependents covered to age 26 regardless of access to other coverage(s).

6) Deductible maximums and metallic level plan requirements for small groups (under 50 eligible employees).

7) Modified Community Rating for small groups at renewal in 2014.

8) ACA Fees to apply to all group plans in 2014.

Please contact Anco Insurance if you have any questions.

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