Agents

Several revisions to the Affordable Care Act (ACA) over the past few months will impact employers offering self-funded health plans.

Payment for the 2015 transitional reinsurance program under Health Care Reform is due January 15, 2016. The reinsurance fee form must be submitted and payment must be scheduled by November 16, 2015. Plan sponsors of self-funded health plans will owe $44 per covered individual for 2015. The fee is based on the number of covered individuals determined in the first three quarters of the calendar year (January through September).

With the release of the final Forms 1094 and 1095 and accompanying instructions for 2015, the IRS has clarified important items regarding the reporting requirements under Health Care Reform.

In Obergefell v. Hodges, the Supreme Court ruled that the Fourteenth Amendment requires a state to license a marriage between two people of the same sex and to recognize a marriage between two people of the same sex when their marriage was lawfully licensed and performed out of state.

IRS Code 6055 requires sponsors of self-funded health plans to file reports with the IRS to verify whether an individual had minimum essential coverage during a given calendar year to satisfy the individual mandate. IRS Code 6056 requires an applicable large employer to file reports with the IRS to verify whether it offered minimum value and affordable coverage to full-time employees and their dependents in a given calendar year to satisfy the employer mandate.