In This Issue
PPACA Reporting Delayed One Year
Employers Asked to Complete "Coverage Tool"
Feds Publish Rules on Incentives
Employment-Based Health Care Costs
New SHRM Survey Reports
2013 EEO-1 Survey
Mandatory Reporting Under PPACA Delayed One Year
The effective date of two provisions of the Patient Protection and Affordable Care Act (PPACA) that require covered employers (50 or more full-time employees) to provide health insurance for their workers or pay a fine were delayed until January 1, 2015. In a July 2nd blog posting, a Treasury Department official stated that the decision to roll back the implementation date was made after "several months" of negotiations with businesses. The Internal Revenue Service later issued more formal guidance on the one-year delay. The PPACA includes information reporting requirements by insurers, self-insuring employers, and other parties that provide health coverage. It also requires information reporting by certain employers with respect to the health coverage offered to their full-time employees. Proposed rules implementing these provisions are expected to be published later this summer. Once the rules have been issued, employers, insurers, and other reporting entities will be strongly encouraged to voluntarily comply with the reporting requirements in 2014, in preparation for the full application of the provisions in 2015. This delay will make it difficult to determine which employers owe shared responsibility payments for 2014. Therefore, employer shared responsibility payments (fines) will also not apply for 2014.
Employers Asked to Complete "Coverage Tool" When Employees Apply for Exchange Coverage
In May 2013, the Department of Health and Human Services (HHS) issued a final application package to be used by individuals enrolling in health coverage through the insurance exchange, now referred to as the Health Insurance Marketplace. The HHS package of applications includes three versions, one of which is a 12 page Application for Health Coverage & Help Paying Costs which can be used by single individuals, and those with a family, who are offered health coverage from an employer. This version of the application includes an Employer Coverage Tool which employers will be asked to complete to enable an applicant to answer specific questions in the application. The Employer Coverage Tool requests information on the employer's health plan. The employer's completed Employer Coverage Tool is not to be included when the application is submitted. Instead, the applicant uses the information provided by the employer to answer similar questions asked in the Health Coverage From Jobs section of the application. The information provided in the Employer Coverage Tool will help determine whether the applicant is eligible for federal premium tax credits and subsidies and, in turn, whether the employer is liable for penalties under the Patient Protection and Affordable Care Act (PPACA) play-or-pay requirements. The application can be completed when the initial enrollment period for the Health Insurance Marketplace begins on October 1, 2013. Employers that anticipate that at least some of their employees will apply for coverage in the public Health Insurance Marketplace should begin reviewing the application and Employer Coverage Tool.
Feds Publish Rules on Incentives for Nondiscriminatory Wellness Programs in Group Health Plans
The U.S. Departments of Health and Human Services, Labor and the Treasury have issued final rules on employment-based wellness programs. The final rules support "participatory wellness programs," which generally are available without regard to an individual's health status. These include programs that reimburse for the cost of membership in a fitness center; that provide a reward to employees for attending a no-cost health education seminar; or that reward employees who complete a health risk assessment without requiring them to take further action. The rules also outline standards for nondiscriminatory "health-contingent wellness programs," which generally reward individuals who meet a specific standard related to their health. Examples of health-contingent wellness programs include programs that provide a reward to those who do not use, or decrease their use of, tobacco, or programs that reward those who achieve a specified health-related goal such as a specified cholesterol level, weight, or body mass index, as well as those who fail to meet such goals but take certain other healthy actions. The rules increase the maximum reward that may be offered under appropriately designed wellness programs, including outcome-based programs and require that health-contingent wellness programs be reasonably designed, be uniformly available to all similarly situated individuals, and accommodate recommendations made at any time by an individual's physician based on medical appropriateness. The rules will be effective for plan years beginning on or after January 1, 2014.
Employment-Based Health Care Costs Continue to Escalate
In 2013 the cost of health care for the average family of four receiving coverage through an employer-sponsored preferred provider organization (PPO) plan is $22,030, according to the 2013 Milliman Medical Index (MMI). The cost share between employer and employee has the employer, on average, paying $12,886 while the employee pays the remaining $9,144 in the form of payroll deductions and out-of-pocket costs. On average, an employee pays $5,544 in payroll deductions and $3,600 in out-of-pocket costs. This represents an increase of 6.5 percent compared with last year's total employee cost of $8,584.
New SHRM Survey Reports on Employer Healthcare Reform Strategies
A new two-part report detailing how U.S. employers are responding to health care reform was published by the Society for Human Resource Management (SHRM) on June 16, in conjunction with its Annual Conference and Exposition. Part one, Health Care Reform-Challenges and Strategies, examines the difficulties that human resources professionals are facing and the strategies they are using to handle the new regulations. Part two, Health Care Reform-Impact of Health Care Coverage and Costs, focuses on future health care coverage benefits and expected costs. In addition, a two-page summary of the survey findings is presented in SHRM Research Spotlight: Health Care Reform-Challenges and Costs. The research was conducted in May 2013. The Society received 818 responses from a randomly selected sample of SHRM members.
2013 EEO-1 Survey Now Available Online
The Employer Information Report EEO-1, is required to be filed with the U.S. Equal Employment Opportunity Commission's EEO-1 Joint Reporting Committee. Reports must be submitted and certified by September 30, 2013. All employers doing business at only one establishment in one location must complete a single Standard Form 100, or use one of the alternate filing methods. All multi-establishment employers must file a report covering the principal or headquarters office, a separate report for each establishment employing 50 or more persons, a consolidated report that must include all employees in establishments with 50 or more employees as well as establishments with fewer than 50 employees, and a list, showing the name, address, total employment and major activity for each establishment employing fewer than 50 persons. One method for completing the EEO-1 report is the web-based online filing system. Online filing requires firms to log into the company's database with a Login ID and Password, contained in the annual Notification Letter. All companies that filed the EEO-1 report for the 2012 reporting period should have received the 2013 EEO-1 Notification Letter by mail by the end of July 2013.
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