Compliance Corner

Are you keeping up on compliance? Upcoming deadlines and updates of note:

Transitional Reinsurance Contributions

HHS has announced that this contribution can be made in either one or two payments again for 2016. (Earlier, it was anticipated that the 2016 payment could only be made in two installments.) For your budgeting and planning purposes, please note the upcoming deadlines related to this program:

  • Nov. 15, 2015: Second 2015 payment of $11 per covered life due. Groups that have already paid the entire amount, $44 per covered life, will not need to make a payment at this time.
  • Jan. 15, 2016: First 2016 contribution due. Groups may make the entire payment of $27 per covered life, or may simply make the first of two payments, which works out to $21.60 per covered life.
  • Nov. 15, 2016:  Second and final contribution due, for those groups choosing to make the payment in two installments.  This second payment will be $5.40 per covered life.

Employer and Individual Mandates: Additional Info

HF-ENewsletter-1-Pic-031Earlier this year, HealthFirst issued recommendations on how self-funded plans should be preparing to comply with the individual and employer mandates. These new responsibilities are outlined in IRS Section 6055 and IRS Section 6056.

Most self-funded groups will file forms 1094C and 1095C. Smaller groups, with under 50 employees, will file 1094B and 1095B.

In general, these forms must be filed for all covered employees. However, groups should be aware that they must also file applicable forms for any retirees on the plan AND any individuals on COBRA during the plan year. Please make sure you are tracking information appropriately for all these individuals.