Ok, you legal eagles. Help me understand these new regs dropped on our laps on Friday. This is how I'm reading it:
1. Employer notifications of exchanges are delayed, and not required in March anymore.
2. HRA's integrated with a group plan are allowed and will avoid the ER penalty. BUT, HRA's that are tied to individual policies, do NOT satisfy employer requirements (for those over 50 EE's), and therefore would be subject to penalties. (if correct, there goes the HRA/private plans exchange model for larger employers).
3. Indemnity plans can NOT be paid on a per service basis (per dr visit), but instead on a per period basis (per day), and are allowed in conjunction with a group plan. Meaning, indemnity plans stand alone would not qualify to avoid the ER penalty.
4. Lastly, they are stating that the employer must pay at least 60% of the group health premiums, or EE can go get subsidies on the exchange. Does this replace the 9.5% of AIG requirement? Where are they getting this number from?
Here are the regs, please help me understand in layman's terms what the hell they are saying:
Affordable Care Act Implementation FAQs - Set 11 | cciio.cms.gov
FAQs About Affordable Care Act Implementation Part XI
Patient Protection and Affordable Care Act (All guidance from DOL)
1. Employer notifications of exchanges are delayed, and not required in March anymore.
2. HRA's integrated with a group plan are allowed and will avoid the ER penalty. BUT, HRA's that are tied to individual policies, do NOT satisfy employer requirements (for those over 50 EE's), and therefore would be subject to penalties. (if correct, there goes the HRA/private plans exchange model for larger employers).
3. Indemnity plans can NOT be paid on a per service basis (per dr visit), but instead on a per period basis (per day), and are allowed in conjunction with a group plan. Meaning, indemnity plans stand alone would not qualify to avoid the ER penalty.
4. Lastly, they are stating that the employer must pay at least 60% of the group health premiums, or EE can go get subsidies on the exchange. Does this replace the 9.5% of AIG requirement? Where are they getting this number from?
Here are the regs, please help me understand in layman's terms what the hell they are saying:
Affordable Care Act Implementation FAQs - Set 11 | cciio.cms.gov
FAQs About Affordable Care Act Implementation Part XI
Patient Protection and Affordable Care Act (All guidance from DOL)