Starting this week, letters will be mailed to Starmark® employers with a self-funded plan design providing information on the status of dependent social security numbers (SSNs). This will help with their 2016 ACA 6055/6056 filing requirements by letting them know if we are missing SSNs for any covered dependents. The broker of record will receive a copy of their group(s) letter.
If the employer has any covered dependents in 2015 with missing SSNs, or adds a dependent later with a missing SSN, they can log in to the Starmark website and update the information under Manage My Group > Dependent SSN Update. The initiative by the employer to obtain and update all missing information will help to ensure that the January 2016 report available in the Document Center will be as complete as possible.
It is the employers’ responsibility to collect the pertinent information and file the appropriate documents with the IRS for all employees. Employers should consult a professional benefit adviser or legal counsel regarding how the law may impact their business and specific self-funded benefit plan.
View the letters below:
Social security numbers missing
In a widely anticipated ruling, the U.S. Supreme Court issued a decision upholding the payment of subsidies to consumers who obtain health insurance coverage through the federal marketplace or exchange..
On June 25, 2015, the Court ruled that federal tax subsidies should be provided to millions of lower- and middle-income Americans who purchased individual health insurance in approximately three dozen states through the federal marketplace or exchange..
The Obama administration had contended that the Patient Protection and Affordable Care Act (PPACA) extends the subsidies to Americans who purchase health insurance through the federal marketplace and through exchanges established by states. However, challengers maintained the law limits the subsidies to individuals who purchased health insurance only through a state exchange.
The Court’s Opinion is available at: http://www.supremecourt.gov/opinions/14pdf/14-114_qol1.pdf
The Internal Revenue Service has released a chart designed to help determine the filing due date and applicable rate for the Patient-Centered Outcomes Research Institute (PCORI) fee, based on when a plan year ends.
Follow this link for more information about the PCORI fee. To view the chart, click here.
The U.S. Departments of Labor, Health and Human Services and the Treasury have released a set of frequently asked questions (FAQs) about coverage of preventive services under the Patient Protection and Affordable Care Act. The questions and answers are related to coverage of BRCA testing, contraceptives, sex-specific recommended preventive services, well-woman preventive care for dependents and colonoscopies.
To read the FAQ document, click here.
The U.S. Departments of Health and Human Services, Labor and the Treasury reaffirmed that a group health plan’s annual in-network out-of-pocket maximum for Essential Health Benefits* cannot exceed $6,850 for self-only coverage and $13,700 for all other coverage. The final regulation also clarifies that the in-network individual out-of-pocket maximum applies to all individuals, regardless of whether the individual is covered by a self-only or family plan (including a high-deductible health plan).
This requirement is applicable for plan and policy years that begin on or after 2016. As a result, family coverage offered to an insured large group or self-funded group in 2016 must have maximum out-of-pocket limits on Essential Health Benefits that do not exceed $6,850 for each individual (the approved maximum out-of-pocket limits for self-only coverage) and $13,700 for the entire family (the approved maximum out-of-pocket limits for family coverage).
Previously, the Centers for Medicare and Medicaid Services had indicated this requirement would apply to the individual and small group insurance market, but it was not clear from its announcement if the restrictions also applied to the large group market and to self-funded group health plans. A new document clarifies that the restrictions apply to all non-grandfathered policies and plans beginning on or after 2016.
The departments issued the guidance in “FAQs About Affordable Care Act Implementation (Part XXVII).”
*ERISA self-funded plans do not have to include 10 categories of benefits known as Essential Health Benefits (EHBs). However, if such self-funded plans do include EHBs for plan years beginning on or after Jan. 1, 2014, they are prohibited by PPACA from imposing lifetime or annual dollar limits on these benefits.
This week, Starmark® employers with a self-funded health plan design who are required to pay the Patient-Centered Outcomes Research Institute (PCORI) fee will receive a letter via mail providing their group’s “average covered lives” (using the Snapshot Count method).
As a courtesy, the Broker of Record will receive a duplicate copy of the letter sent to their group(s). The letter will also be posted to the Document Center on the Starmark website for the employer, the Broker of Record and the broker’s managing general agent to view.
The Patient Protection and Affordable Care Act requires health insurance issuers and plan sponsors of self-funded group policies be assessed an annual PCORI fee, previously known as the comparative effectiveness research fee.
Plan sponsors of self-funded health plans are responsible for filing and paying the PCORI fee. Sponsors of plan years ending in 2014, are required to send the fee to the IRS on Form 720 by July 31, 2015.
Click here to view a sample letter.
The proposed deadline for providing revised Summaries of Benefits and Coverage and Glossary of Terms (collectively, SBC templates) to health plan members has been delayed.
In December 2014, the U.S. Departments of Labor, Health and Human Services and the Treasury proposed changes to the SBC regulations and SBC templates that would take effect Sept. 1, 2015.
However, the departments recently released a Frequently Asked Question (FAQ) that indicates the proposed regulations will apply to plan years new or renewing on or after Jan. 1, 2016. Revised SBC templates will be finalized by January 2016 and will apply to health coverage that would renew or begin on the first day of the first plan year that begins on or after Jan. 1, 2017.
Read this FAQ for more information.