Grandfathered Plan Status
□ If you have a grandfathered plan, determine whether it will maintain its grandfathered status for the 2015 plan year. Grandfathered plans are exempt from some of the ACA’s requirements. A grandfathered plan’s status will affect its compliance obligations from year to year.
□ If your plan will lose grandfathered status for 2015, confirm that the plan has all of the additional patient rights and benefits required by the ACA. This includes, for example, coverage of preventive care without cost-sharing requirements.
□ Review your plan’s out-of-pocket maximum to make sure it complies with the ACA’s limits for the 2015 plan year ($6,600 for self-only coverage and $13,200 for family coverage).
□ If you have a health savings account (HSA)-compatible high deductible health plan (HDHP), keep in mind that your plan’s out-of-pocket maximum must be lower than the ACA’s limit. For 2015, the out-of-pocket maximum limit for HDHPs is $6,450 for self-only coverage and $12,900 for family coverage.
□ If your plan uses multiple service providers to administer benefits, confirm that the plan will coordinate all claims for EHB across the plan’s service providers, or will divide the out-of-pocket maximum across the categories of benefits, with a combined limit that does not exceed the maximum for 2015.
□ Be aware that the ACA’s annual deductible limit no longer applies to small insured health plans.
Health FSA Contributions
□ Work with your advisors to monitor IRS guidance on the health FSA limit for 2015.
□ Once the 2015 limit is announced by the IRS, confirm that your health FSA will not allow employees to make pre-tax contributions in excess of that amount for 2015. Also, communicate the 2015 health FSA limit to employees as part of the open enrollment process.
Transition Policy for Small Group Health Plans
□ Pre-existing Condition Exclusions—The ACA prohibits health plans from imposing pre-existing condition exclusions (PCEs) on any enrollees. (PCEs for enrollees under 19 years of age were eliminated by the ACA for plan years beginning on or after Sept. 23, 2010).
□ Coverage for Clinical Trial Participants—Non-grandfathered health plans cannot terminate coverage because an individual chooses to participate in a clinical trial for cancer or other life-threatening diseases or deny coverage for routine care that would otherwise be provided just because an individual is enrolled in a clinical trial.
□ Comprehensive Benefits Package—Insured plans in the individual and small group market must cover each of the essential benefits categories listed under the ACA. Each state has a specific benchmark plan for determining the essential health benefits for insurance coverage in that state.
Employer Penalty Rules
□ Determine ALE status for 2015, including eligibility for the one-year delay for medium-sized ALEs;
□ For sponsors of non-calendar year plans, determine whether you qualify for the transition relief that allows you to delay complying with the pay or play rules until the start of your 2015 plan year;
□ Establish a system for identifying full-time employees (those working 30 or more hours per week);
□ Document plan eligibility rules; and
□ Test your health plan for affordability and minimum value.
HSA Limits for 2015
If you offer a high deductible health plan (HDHP) to your employees that is compatible with a health savings account (HSA), you should confirm that the HDHP’s minimum deductible and out-of-pocket maximum comply with the 2015 limits. Also, the 2015 increased HSA contribution limits should be communicated to participants. The following table contains the HDHP and HSA contribution limits for 2015.
HDHP Minimum Deductible Amount
HDHP Maximum Out-of-Pocket Amount
HSA Maximum Contribution Amount
Catch-up Contributions (age 55 or older) $1,000
For more information please contact The Benefits Firm.
Ph: (502) 451-4560
620 S. 3rd Street, Suite 102 Louisville, KY 40202