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Sunday, 10 November 2013 10:00

Clarification on the Individual Mandate Penalty

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 Many are confused about when the individual mandate is actually effective.  It DOES still go into effect in 2014, unlike the employer mandate which has been delayed in its entirety to 2015. Initially, the mandate would be considered to be satisfied if you had a gap of no more than two months of coverage, which would require individuals to enroll in coverage by March 1st.  However, there has been some new guidance issued just this month clarifying that individuals who enroll through the marketplace have until March 31st to select their coverage. Enrolling this late, however, means coverage would not be effective until  April or May, due to the rule requiring individuals to be enrolled by the 15th of the month prior to starting coverage. Because the enrollment period in the marketplace goes until March 31 this first year, the Department of Health and Human Services (HHS) has clarified that individuals who enroll by March 31, 2014 in the marketplace WILL qualify for a hardship exemption from the mandate, even if their coverage does not start until April 1 or even May 1. Drop us a line or read more here if you have any further questions about this!

 

On October 31, the US Treasury released guidance indicating that employers may now offer the option of rolling over up to $500 of unused Flexible Spending Account dollars to a future plan year.  This is big news because it takes away one of the biggest fears employees have about using an FSA.  There’s really no reason now for an eligible employee to NOT enroll in the FSA for at least $500, now that it can roll over indefinitely.
Note that if an employee rolls over $500, he or she may still elect the entire amount allowed under your FSA plan for the following year (up to an IRS max of $2,500). If they don’t use it all, however, they can only roll over the same $500 next year.
Employers now have three choices when it comes to designing an FSA:
  1. Continue to enforce the “Use-it-or-Lose-it” Rule that means any unused dollars at the end of the plan year revert to the employer.
  2. Take advantage of a 2 ½ month grace period which allows your employees to have extra time to INCUR claims, not just submit receipts.  This allows UNLIMITED rollover in terms of dollar amounts, but a LIMIT in terms of time to use it. This grace period cannot be used in conjunction with the new $500 rollover.
  3. Jump on this newly available third option, of allowing a $500 rollover.  This works the opposite of option 2, giving the employee only a LIMITED dollar amount, but UNLIMITED time to use that $500.
You may amend your plan document right now for the plan year that is already in progress (IF you don’t already offer the 2 ½ month grace period), to allow employees to rollover up to $500 of the dollar amounts already elected.  Or, you can wait until the following plan year to put in place ANY of the three options above.
We recommend choosing the new option of the $500 rollover as the most employee-friendly option, to encourage the highest FSA participation possible. Give us a call or This email address is being protected from spambots. You need JavaScript enabled to view it. with any questions.

Higher Premiums & Greater Employee Cost-Sharing

The Kaiser Family Foundation released their “Employer Health Benefits – 2010 Summary of Findings” on September 2nd, 2010.

Higher Premiums & Greater Employee Cost-Sharing

The Kaiser Family Foundation released their “Employer Health Benefits – 2010 Summary of Findings” on September 2nd, 2010.

Amidst the economic upheaval, the numbers clearly suggest two trends.

What trends can you expect in employee benefits for 2011? What financial impacts did healthcare reform have on the average renewal?

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