RGL "PIPELINE"

 

 

  

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 13724 Venetian Court

Orland Park, Illinois 60467
Office 708-301-6425 
 Fax:  708-301-6455
  

 

Providing Human Resources Consulting for Small to Mid-Size Organizations

 

July, 2013

Top 

Greetings!

 

The Affordable Care Act is "the law of the land" and we must, as employers, still plan ahead for its full implementation.  This is difficult enough given the complexity of the program, but is complicated further by continued uncertainty and government delays.

 

One "deliverable" that we can and should deal with now is determining our employee headcount for compliance purposes based upon the Act's specified methodology.  If in 2013, you have (or had) 50 or more Full time (including FTE) employees, you are considered a "large employer" for 2014 and must offer/provide health insurance to all Full-time employees (employees working 30 or more hours per week) that pays at least 60% of covered expenses and does not cost the employee more than 9.5% of their household income in order to avoid the "shared responsibility penalty".  Remember, common ownership/"controlled group" rules apply in making this calculation.

 

To complete the required calculation for part-time, seasonal, and variable hour staff members, you can determine the applicable  "measurement period", "stability period", and "administrative period". 

 

It is strongly suggested that once you complete this required calculation, the results be documented and retained for possible audit purposes.    

 

If you would like assistance in completing this task, please contact us.

  

 

Healthcare Reform  OBAMACARE DEVELOPMENTS
  
 
Another couple of "speed bumps" have surfaced regarding implementation of the "Affordable Healthcare Act". 
  
First, SHOP (Small Business Health Option Program) for businesses with fewer than 100 employees, intended as a vehicle to allow employers to offer employees a variety of qualified health plans from which to choose to fit their needs and their budgets, is being delayed until 2015.  In the meantime, it is planned to offer just one option in 2014, but it is uncertain if this will be ready for the October 1, 2013 Open Enrollment Rollout.
  
Second, on June 19th, the General Accounting Office released a report finding that the government is not prepared to facilitate the creation of health insurance exchanges that allow individuals to purchase insurance in the 34 states that have refused to set them up. Of these 34, 15 have agreed to help the Centers for Medicare and Medicaid Services (CMS) set up exchanges. GAO determined that CMS is not prepared to do so.
 

Key findings from the GAO Report:

 

* States have yet to complete 85 percent of the required program activities. GAO found that, "...states had between 16 and 52 key activities remaining to be completed, or on average, about 85 percent of their total key activities [actions that must be completed before October 1, 2013]."

 

* Core functions of both federal and state-based exchanges have yet to be completed. According to GAO, "[The Center for Medicare and Medicaid Services] (CMS) has many key activities remaining to be completed across the core exchange functions - eligibility and enrollment, including development and implementation of the data hub; program management; and consumer assistance."

 

* With less than four months before open enrollment, any other missed deadlines threaten the timely establishment of exchanges. The GAO reported that "...much remains to be accomplished by CMS and states within a relatively short amount of time." The reports also noted that missed deadlines closer to the start of enrollment could impact the establishment of exchanges.

 

* HHS has yet to complete critical steps needed to determine eligibility for credits and cost-sharing subsidies. GAO found that, "CMS ... still needed to complete steps to enable FFEs to be ready to test development of key eligibility and enrollment functions, including calculation of advance payments of the premium tax credits and cost-sharing subsidies, verification of consumer income, and verification of citizenship or lawful presence."

 

* Key data sharing agreements between the federal exchange and its federal and state partners have yet to be complete. GAO reported that "...several critical tasks remain to be completed before the October 1, 2013, implementation milestone." These tasks include Service Level Agreements (SLAs) between CMS and state and federal agencies, which are necessary to make eligibility determinations.

 

* Consumer assistance and outreach activities to individuals and employers has been delayed. GAO found that, "CMS has yet to complete many activities related to consumer assistance and outreach and some initial steps were behind schedule." Such activities not yet complete include "...the federal call center, healthcare.gov website, media outreach, and consumer complaint tracking systems for the [Federally Facilitated] FF-SHOP and [Federally Facilitated Exchanges] FFEs."

 

The scope of CMS involvement in exchange activities remains unclear. If a state does not "make adequate progress," CMS is expected to step in. According to the GAO, CMS has yet to grant final approval for any state seeking to operate an exchange. The GAO also notes that "some of these exchanges may be under conditional approval when enrollment begins."

  

 

Issue:49

 

 
 

We encourage you to forward this Newsletter to colleagues or others whom you feel would be interested in receiving the RGL Pipeline
  
 

 

KEEP, MODIFY, OR DROP YOUR HEALTH INSURANCE PLAN?

 

Despite the potential for increased costs and more regulatory red tape, 82% of companies recently surveyed by Challenger, Gray & Christmas, Inc. have already decided to continue providing health care coverage to their workers when the employee mandate provision of the Affordable Care Act goes into effect on January 1, 2014.  Surprisingly, none of the 100 human resources executives surveyed by Challenger said that their companies plan to drop health coverage when the mandate begins.

 

 

 

 

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Regards from,

   Dave                        Rich                          Jim
  Dave Slivinski                                       Rich Lehr                                          Jim Kacena

  Consultant                                           President                                    Consultant/Coach

 

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