REGIT, Inc. has had the privilege of meeting the insurance needs of hundreds of IRA members over the years. With the implementation of the Affordable Care Act (ACA), key parts of the new law are emerging weekly. Even though key provisions of the new law regarding employer penalties for employers with 50 or more employees has been postponed you still need to understand the impact the legislation will have on your business and to avoid future penalties for non-compliance, but your focus must remain on your business. That’s why the role of your insurance broker is more important now than ever.
Dave Brennan is the Executive Vice President of REGIT and primary contact for Illinois Restaurant Association members and has over 40 years experience working in the Association and Group health insurance marketplaces. REGIT's focus is to see that IRA members have the best products available, and to educate them on the new facets of the law as well as the penalties for non-compliance. This is done routinely through articles, emails, and thier website, all of which are accessible from a link on the IRA website.
Below are excerpts from a piece recently sent to their clients:
- Please take a moment to read this important notice about your responsibilities as an employer under health care reform. The requirement to notify employees of coverage options applies to all employers regardless of size.
On May 8, 2013, the Department of Labor (DOL) issued Technical Release 2013-02 which provides temporary guidance for employers regarding the requirement to notify employees of coverage options available through Exchanges, also called Health Insurance Marketplaces.
This Model Notice to Employees of Coverage Options is available for employers to use today if they wish. Employers must provide notice to current employees by October 1, 2013.
There are two model notices. Both forms require the employer to enter specific information before distributing to employees.
- Model Notice for employers who offer a health plan
- Model Notice for employers who do NOT offer a health plan.
Employers may use one of these models, as applicable, or a modified version, provided the notice meets the content requirements. The notice must be provided in writing in a manner understood by the average employee. The notice may be provided to employees by first-class mail or electronically if in accordance with the DOL regulations.
REGIT will not be creating a version of this notice and since it is unclear at this time whether insurance carriers will be providing support to clients as they complete these notices, employers may use the DOL version if they wish. Providing notice of coverage options is an employer obligation. Employers may want to use the Minimum Value Calculator posted on The Center for Consumer Information & Insurance Oversight website to determine if their plan meets the minimum value requirements.
What Must the Notice Include?
The notice to inform employees of coverage options must include information regarding the existence of an Exchange as well as contact information and description of the services it provides. The notice must include:
- Information regarding the existence of the Exchanges as well as contact information and description of the services provided by an Exchange;
- A statement informing the employee that if the employee purchases a qualified health plan through the Exchange, the employee may lose the employer contribution(if any) to any health benefits plans offered by the employer and that all or a portion of such contribution may be excludable from income for Federal income tax purposes; and
- If the employer plan’s share of the total allowed costs of benefits provided under the plan is less than 60 percent of such costs, the employee may be eligible for a premium tax credit if the employee purchases a qualified health plan through the Exchange.
What is the Deadline that Employers Must Issue the Notice to Employees?
Current employees must receive the notice before October 1, 2013. The notice is required to be provided automatically, free of charge. Employers are required to provide the notice to each new employee at the time of hiring beginning October 1, 2013. For 2014, the DOL will consider a notice to be provided at the time of hiring if the notice is provided within 14 days of an employee’s start date.
Model COBRA Election Notice Available
The model COBRA election notice is available in modifiable, electronic form:
- Some qualified beneficiaries may want to consider and compare health coverage alternatives to COBRA continuation coverage that are available through the Exchange as they may also be eligible for a premium tax credit. Therefore, the DOL has revised the COBRA model election notice to help make qualified beneficiaries aware of other coverage options available in the Exchanges.
- The notice also includes a new notation that plans may no longer impose any pre-existing condition exclusions beginning in 2014 pursuant to the ACA, and not just those tied to covered individuals under the age of 19.
COBRA Model General Notice
For more information, visit the DOL website.
REGIT will keep their clients posted on future ACA employer requirements. In the meantime please visit REGIT’s web site at www.regitinc.com for more posts.
There are many more provisions to this new law and whether you are a small business with up to 50 employees, or one with 50 or more REGIT stands ready to provide professional assistance. REGIT, Inc., IRA’s preferred Insurance Broker, will assist you with coverage and compliance questions.
Contact David E. Brennan, EVP, REGIT, Inc. at:
1200 Roosevelt Road, Suite 115
Glen Ellyn, IL 60137
Direct Tel: 630.652.1061
Toll Free: 800.537.9786
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