Notice of Subsidies in the Federal Marketplace

The Affordable Care Act (“ACA”) requires each Health Insurance Marketplace (“Marketplace”) to notify any employer whose employee was determined to be eligible for Advance Premium Tax Credits (“APTC”) and Cost Sharing Reductions (“CSR”) because the employee attested that he or she was not: • enrolled in employer sponsored coverage, or • eligible for employer coverage that is affordable and meets minimum value requirements. In 2016, the Federally-Facilitated Marketplace (“FFM”) will begin issuing these notices to employers. State-based Marketplaces began this notification process in 2015. Click the link to download the complete bulletin. Download Notice of Subsidies in the Federal Marketplace

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Health Reform: Draft 2015 Form 1095-C and Instructions, Increased Penalties, and Electronic Filing Steps Issued

  On August 7, 2015, the IRS issued revised draft 2015 Form 1095-C with instructions. The forms and instructions are substantially the same as those applicable to the 2014 year, but the penalties have been revised. Click here to download this important update for all applicable large employers. As always if you have any questions or concerns about your organization’s health care reform compliance, please contact your Total Benefit Solutions, Inc account manager at (215)355-2121

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HR 360: How to Calculate Pay or Play Penalties

HR 360: How to Calculate Pay or Play Penalties: Make sure you are ready for 2015 with our basic step-by-step guidance on calculating pay or play penalties. This attorney-reviewed guide, provided by our partner HR360,  makes it easy to understand how to calculate ACA penalties. HR360 is provided as a service to Total Benefit Solutions clients. If you have any additional questions regarding this bulletin, or the Affordable Care Act, please contact your Total Benefit Solutions account manager at (215)355-2121 Download How to Calculate Pay or Play Penalties    

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Health Reform: Guidance Issued-Employer Reimbursement of Individual Policies

  Previously, the Departments of Labor (“DOL”), Health and Human Services (“HHS”) and the Treasury (collectively, the “Departments”) explained that  HRAs and employer payment plans cannot reimburse individual policies. On November 6, the Departments issued their twenty-second set of FAQs which make clear that: An employer cannot offer employees cash to reimburse the purchase of an individual policy, without regard to whether the employer treats the money as pre-tax or post-tax to the employee. Such arrangements are subject to the market reform provisions of the Affordable Care Act (“ACA”), including prohibition on annual limits and the requirement to provide certain preventive services without cost sharing with which it cannot comply. Such… Read More

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