Providers

The Federally Facilitated Marketplaces (FFMs) have begun sending notices informing employers that employees have enrolled in an FFM and were determined to be eligible for premium subsidies.

On April 6, 2016, the Centers for Medicare & Medicaid Services (CMS) published the final template for the Summary of Benefits and Coverage (SBC) and Uniform Glossary. Health plans must use the new SBC template and Uniform Glossary on the first day of the first open enrollment period that begins on or after April 1, 2017, with respect to coverage for plan years beginning on or after that date.

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 Internal Revenue Service (IRS) has released draft reporting forms that employers will use to report the health coverage they offer their employees.

The final regulations of the 90-day waiting-period limitation of the Affordable Care Act clarify how the waiting period will coincide with any employment-based orientation period.