Agents

The Health and Human Services Office of Civil Rights (OCR) has officially begun its Phase 2 Audit Program under HIPAA. Phase 2 audits could involve desk audits or on-site assessments and will be completed by the end of 2016. Covered entities should take steps now to prepare for these audits and to mitigate potential risks.

The Affordable Care Act (ACA) requires applicable large employers (ALEs) with 50 or more full-time employees (including full-time equivalent employees) to offer minimum-value, affordable health coverage to full-time employees and their children or pay a penalty.

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.