Significant Changes under Affordable Care Act

Several revisions to the Affordable Care Act (ACA) over the past few months will impact employers offering self-funded health plans.

Due Dates Extended for 2015 Information Reporting

IRS Notice 2016-4 extends the due dates for the 2015 information reporting requirements for employers offering self-insured health plans:

✓  The due date for furnishing to individuals the 2015 Form 1095-B (Health Coverage) and Form 1095-C (Employer-Provided Health Insurance Offer and Coverage) has been extended from February 1, 2016 to March 31, 2016.

✓  The due date for filing with the IRS the 2015 Form 1094-B (Transmittal of Health Coverage Information Returns), Form 1095-B (Health Coverage), Form 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns), and Form 1095-C (Employer-Provided Health Insurance Offer and Coverage) has been extended from February 29, 2016 to May 31, 2016. If filing electronically, this deadline has been extended from March 31, 2016 to June 30, 2016.

Cadillac Tax Delayed

The effective date of the Cadillac tax has been delayed until 2020 (tax years beginning after 2019). And when the tax does take effect, it will be deductible—originally, it was to be nondeductible. The legislation also requires a report to Congress, within 18 months, regarding the suitability of the designated benchmarks for determining age and gender adjustments when calculating whether the tax is due.

Automatic Enrollment Repealed

Under the auto-enrollment provision that the ACA added to the Fair Labor Standards Act (FLSA), employers subject to the FLSA that employed more than 200 full-time employees would have to automatically enroll new full-time employees in one of their health benefit plans. On November 2, 2015, H.R. 1314 repealed the automatic enrollment requirement under the ACA.

If you have questions about these changes, call ASR Health Benefits at (616) 957-1751 or (800) 968-2449.