Seven Steps to Health Care Reform

By: Bonnie Pang, Senior Vice President Benefits Consulting

President Trump’s promise to repeal Obamacare looks less and less probable these days, but it is tough to know precisely what lies ahead. Regardless of what happens, it is necessary for you to “put your blinders on” for the moment and continue to fulfill your reporting requirements on schedule. Here, we list some of the documents regarding your employer health plan that you must file on an ongoing basis:

1) HC-5 EMPLOYEE NOTIFICATION TO EMPLOYER
This document, which confirms that an employee has elected to waive health care coverage through his or her employer, must be signed and renewed each January. This form is generally used by those who are covered under another employer’s health plan or the health plan of a parent or spouse

2) INDIVIDUAL CREDITABLE COVERAGE DISCLOSURE NOTICE

This document confirms that the drug coverage provided by an employer meets the minimum requirements defined by Medicare. The form must be distributed by October 15th of each year to all Medicare-eligible employees—including dependents—who are covered by the employer plan. Atlas further recommends that the notice be distributed to all employees.

3) NEW HEALTH INSURANCE MARKETPLACE COVERAGE OPTIONS AND YOUR HEALTH COVERAGE

This notice, informing individuals of their eligibility to enroll in the Health Care Exchange, is required for newly hired employees who are subject to the Fair Labor Standards Act. Atlas further recommends that the notice be distributed to all employees.

4) SUMMARY PLAN DESCRIPTION (SPD)
The SPD, along with an overview description of the document, must be provided to all plan participants. Updates or modifications to the SPD should be provided to each covered employee, including those covered under COBRA as they occur.

5) SUMMARY OF BENEFITS AND COVERAGES (SBC)
The SBC, which describes how benefits are received, must be provided to new hires for all plans for which they are eligible. It also must be distributed to all employees enrolled in the plan at least 30 days prior to the contract renewal date.

6) FORM 5500 REPORT

This report summarizes the total premiums and commissions paid as well as the number of people covered under the plan. The 5500 report must be filed to EBSA by the 7th month after the end of the plan year. The accompanying Summary Annual Report must be provided to each plan participant by the end of the ninth month after the plan year ends.

7) GRANDFATHER NOTICE

If applicable, this notice, confirming that the plan has not made significant changes to its design or contributions since March 23, 2010 when the Affordable Care Act went into effect, must be distributed to each newly eligible and current enrollee in the employer plan annually.

Contact a Benefits Consulting Specialist

Atlas Insurance has been advising clients on employee health benefit plans for decades and is available to answer questions, discuss individual reporting obligations, and review coverage options.

You can reach out to Bonnie directly by calling her at 808-533-8651 or email at bpang@atlasinsurance.com.