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2015
2015
Large Group
The ACA
There are numerous rules and regulations on both
federal and state levels that employers need to
implement in order to be in compliance with this
new law.
Many provisions of the
ACA have already been
implemented and others
will become effective for
calendar year 2015.
Waiting PeriodThe ACA Limitation on Waiting Periods is 90 days.
Effective January 1, 2015, the waiting period in
California will change from 60 days to 90 days.
The ACA also allows a maximum one-month orientation period immediately
before the waiting period begins.
Waiting Period
For All Groups
Waiting Period
For Large Groups
Waiting Period
COVERAGE STARTS
9/1/14
WAITING PERIOD
6/3/14 – 8/31/14
ORIENTATION PERIOD
5/3/14 – 6/2/14
COVERAGE STARTS
1/30/15
WAITING PERIOD
11/1/14 – 1/29/15
ORIENTATION PERIOD
10/1/14 – 10/31/14
COVERAGE STARTS
5/30/15
WAITING PERIOD
3/1/15 – 5/29/15
ORIENTATION PERIOD
1/30/15 – 2/28/15
Grandfathered Plans
Grandfathered Plans
Cost-sharing Out-Of-Pocket Limits
$6,600 for self-only coverage
$13,200 for family coverage
Cost-sharing Limits
Review plan’s out-of-pocket maximums
HDHPs - $6,450 for self-only coverage and $12,900 for family
coverage
Can divide OOP maximum across categories of benefits
FSA Contributions
$2,500 Maximum Contribution
$500 rollover to next year
FSA Contributions
Employer Shared Responsibility
Employer Shared Responsibility
1
2
3
4
Identify number of Full-Time Employees
Add up the aggregate hours of all Part-Time
Employees
Take the aggregate hours for Part-Time
Employees for the month and divide by 120
Add total for step 1 and step 3
Employer Shared ResponsibilityControlled Groups
Parent, Inc.
Sub, LLC Sub 2, Inc.
Sister Co., Inc. Affiliate, Inc.
Employer Shared ResponsibilityControlled Groups
Parent = 80 EEs
Sub 1 = 40 EEs
Sub 2 = 10 EEs
130 Full-Time Employees
Parent - 49 EEs
Sub 1 - 25 EEs
Sub 2 - 6 EEs
61% of
Total EEs
31% of
Total EEs
8% of
Total EEs
Minus 80 Employees
Employer Shared Responsibility
Employer Shared ResponsibilityMeasurement Periods
What if an employer
cannot reasonably
determine if a new
employee will be a
full-time employee?
Employer Shared ResponsibilityMeasurement Periods
Employer Shared ResponsibilityMeasurement Periods
Ongoing Employees
Employer Shared ResponsibilityMeasurement Periods
New Employees
Employer Shared ResponsibilityMeasurement Periods
What about seasonal employees?
Employer Shared Responsibility
Penalties
$2,000 per full-time employee
OR
$3,000 per full-time employee receiving a subsidy
Employer Shared Responsibility
Affordability and
Minimum Value
Design-based safe harbor plans that satisfy minimum value
Individual Deductible Coinsurance Individual
Out-of-
Maximum
Prescription
Drug
Copayments
Employer
Individual Annual
HSA Contribution
Medical Prescription
Drug
1 $3,500 integrated
medical and drug
80% all
services
$6,000 N/A N/A
2 $4,500 integrated
medical and drug
70% all
services
$6,400 N/A $500
3 $3,500 $0 60% medical
75%
prescription
drug
$6,400 $10/$20/$50
Specialty
drugs at 75%
N/A
Employer Shared ResponsibilityMinimum Value
Employer Shared Responsibility
Transition Relief
Transition Relief
Grandmothering for Small Employers
Transition Relief
Dependent Coverage
6 Month Look-Back Period
Transition Relief
For Employers With
50–99 Employees
In order to be eligible for the relief, an employer
must meet the following conditions:
Transition Relief
For Employers With 50–99 Employees
Limited Workforce Size
Maintenance of Workforce and Aggregate Hours
of Service
Maintenance of Previously Offered Health
Coverage
Employers who offer non-
calendar year plans are
not required to comply with
the mandate until the start
of their plan year in 2015
provided the plan meets
the following criteria:
Transition Relief
Maintained a non-calendar year plan before
December 27, 2012
Plan year was not modified after December 27, 2012
Eligibility rules were not changed after February 9, 2014
Transition Relief
Employer must have offered
coverage to at least 33% of all
employees or covered at least 25%
of its entire workforce, including
part-time workers.
OR
Has offered coverage to at least
50% of all full-time employees or
covered at least 33% of all full-time
employees.
Transition Relief
Reporting Requirements
Who does it apply to? 6055 (all employers) 6056 (only employers over 50 FTEs)
Fully insured health plans Reported by insurer Reported by employer
Self-insured plans and multi-
employer groups
Reported by employer Reported by employer
Reporting Requirements
Notices
Resources
LISI Employer Checklist
Department of Labor (DOL): www.dol.gov/ebsa
California Department of Managed Health Care:
1-888-466-2219 www.HealthHelp.ca.gov
California Department of Insurance (CDI):
Hot Line: 1-800-927-4357 www.insurance.ca.gov
California Health Benefit Exchange:
www.HealthExchange.ca.gov
Covered California: www.coveredca.com
Healthcare.gov: www.HealthCare.gov
