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We’ve outlined five compliance requirements of the Patient Protection and Affordable Care Act (PPACA) which affect employers and employer-sponsored group health plans. The focus of this checklist is on grandfathered plans, annual and lifetime caps, W-2 health care coverage reporting, summary of benefits and coverage, and the small business health care tax credit. This checklist is designed to help employers who sponsor group health plans review their plan's compliance with the major provisions of the health care reform law which may impact their companies in 2012.
1. Evaluate Grandfathered or Non-Grandfathered Status of Plan
A grandfathered plan is one that was in effect on March 23, 2010 when health care reform legislation was signed into law. If a plan loses its grandfathered status, it may no longer be exempt from certain requirements under health care reform.
2. Review Plan Documents for Required Changes to Plan Benefits
Plan documents should be amended to reflect changes as of the effective dates noted below. Please contact your carrier or employment law attorney for additional details or if you have questions regarding these amendments.
3. Report Employer-Provided Health Plan Coverage on Forms W-2
This requirement does not apply to employers that were required to file fewer than 250 W-2 forms for the preceding calendar year, unless and until the IRS publishes further guidance giving at least 6 months' advance notice of any changes. However, employers should check with their state revenue department for any reporting requirements related to coverage for adult children that may apply for state income tax purposes.
Please Note: This list is for general reference purposes only and is not all-inclusive. The information is subject to change based on new requirements or amendments to the law. Additionally, your group plan may be exempt from certain requirements described in this article. If you have any questions regarding your obligations with respect to health care reform, you should consult with a knowledgeable employment law attorney and your carrier.
Part 2 of the 2012 Health Care Reform Compliance Checklist will be posted to our blog on Friday. Friday’s article will focus on summary of benefits and coverage, the small business health care tax credit, changes to flexible spending accounts, simple cafeteria plans and Medical Loss Ratio rebates.