What Does the Supreme Court Ruling Mean to Business Owners? |
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By now you've probably heard about the Supreme Court's ruling that the Affordable Care Act (ACA) is largely constitutional. What does this outcome mean for you as an employer? For the time being at least, much of the uncertainty has been removed so you should look at the following areas to ensure your legal compliance:
- Summary of Benefits and Coverage (SBC.) Employers sponsoring group health plans should ensure compliance with the SBC provisions. These require distribution of a Summary of Benefits and Coverage regarding your health plan during upcoming open enrollment periods. The summaries must be distributed no later than the first day of the first open enrollment period beginning on or after September 23, 2012.
- Form W-2 Health Care Reporting. Employers that issued fewer than 250 W-2s last year have been given transition relief from the provision that states that forms W-2 for calendar year 2012 (generally provided in January, 2013) and beyond must include the annual cost of group health coverage in Box 12 using code DD. The amount is reported for exemption for 2012 (and perhaps beyond) pending further guidance from the IRS.
- Health Plan Components. Employer group health plans will be prohibited from imposing lifetime or annual maximums on benefit amounts and pre-existing condition limitations by 2014. The law already mandates that plans provide coverage for subscribers' children up to age 26 and that, unless grandfathered, specific preventative care benefits have first dollar coverage.
- Health Flexible Spending Account (FSA) Limits. For plan years beginning in 2013, annual contributions will be limited to $2,500. If you offer an FSA with a higher limit, you'll need to adjust the plan document, communicate the change to employees and provide updated summary plan descriptions.
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