Fully Insured Small Business IRS Aggregate Group Survey Ends August 26

Friday, Aug. 26 marks the end of the Small Business IRS Aggregate Group survey that began the week of July 18.  To collect and validate 1095-B information for the 2016 tax year, a letter was sent to Small Business fully insured employers requesting them to confirm if they are a controlled group, association or the Multiple Employer Welfare Arrangement. The letter included a unique link to an online survey where the employer indicates whether or not they are an aggregate group. Data collected will be used to begin the set-up of the employer EINs in the systems.It is essential that carriers obtain this information now to begin the set-up and testing process and also to allow the employer to begin their own system preparation. Please encourage your clients to complete the survey before August 26.

Enforcement Begins and Penalties are Coming

ACA compliance enforcement has begun and they need to be compliant now. If you or your clients are an employer that decided not to choose a compliant plan or didn’t offer anything at all, the employer may be subject to penalties under the Employer Mandate.

This summer was a big month for the Department of Health and Human Services (HHS). They made two major announcements regarding the process for determining if an employee is eligible for a subsidy under the Affordable Care Act (ACA). HHS announced that they hired a third-party contractor to conduct an “employer verification study” where the contracted company will be calling employers and asking about the health insurance coverage they offer. The purpose of these calls is to determine whether employers have successfully offered an affordable plan that meets the minimum value requirements to their employees.

The need for these calls goes back to the ACA Exchanges, a person must state that they were not offered a plan that was affordable and meets minimum value by their employer. If they were indeed offered an eligible plan, this person would be ineligible for a subsidy.

The Centers for Medicare & Medicaid Services (CMS) state that each call is expected to last 10-15 minutes. “Employer participation will enable CMS to evaluate for plan year 2016 whether an employee, or a sample of employees, correctly attested that he or she was not offered ESC that met affordability and minimum value requirements.” The site also states that participation in this study is voluntary and will only take place between April and June 2016. This process was delayed for 2014 and 2015, but it now seems like the HHS is ready to implement a verification process, and it starts with these calls.

CMS also released a sample notice that the Federal Exchange will send to employers that one of their employees has submitted an application for a subsidy and claims they haven’t been offered compliant coverage

Why does this matter to you?

Well, some employers did everything they needed to do and chose a plan that was compliant, like the ones we offer but the Exchange did not discover that fact during the verification process. The employer will have the opportunity to contact the Exchange and provide documentation that they offered a plan that is affordable and meets minimum value requirements. After the Exchange receives this info, they will re-determine the employee’s eligibility and discontinue any premium subsidy payments.

Let’s talk about our 100% compliant ACA solutions, give us a call asap. Or REQUEST A QUOTE.