Are You Compliant? Affordable Care Act Requirements for 2015

Source Newsletter for Business and Operations Header Image
Source Newsletter for Business and Operations Header Image

Business and Operations//

January 6, 2015

Now that you've returned from a well-deserved winter break, you must ensure your school is ready for the 2015 requirements as outlined in the Affordable Care Act.

Hopefully, you have been counting all your employees’ hours for the past year, including preparation time for teachers. In 2015, you must continue this practice and remember that new part-time employees in 2014 will continue to be counted in an initial measurement period, as well as standard measurement periods. This “counting” allows you to know which, if any, portion of the Affordable Care Act you are required to follow.

To review: If you have 100 or more full-time equivalent (FTE) employees, you will have to offer those employees who work 30 hours per week or more (and their dependents) health insurance that meets both Minimum Value and is defined by law as Affordable.

A quick reminder on the definitions of Minimum Value and Affordable—

Minimum Value: The health insurance must pay an actuarial value of at least, on average, 60% of the cost for health services.

Affordable: The employee’s share of your lowest priced health insurance plan must offer a minimum value that does not cost more than 9.5% of the employee’s W-2 income.

If you have 50 or more FTE Employees, you will be required to report those employees who were offered health insurance. This report will need to be shared with the employee and the IRS in January 2016.

Verify that, with the start of your health insurance policy 2015 plan year, there are:

  1. no waiting periods for new full-time employees longer than 90 days,
  2. no annual dollar limits on essential health benefits, and
  3. if you are a small school, your plan has the comprehensive package offering Essential Health Benefits.

Reminder of how the Essential Health Benefits are defined—

  • Ambulatory patient services
  • Emergency services
  • Hospitalization
  • Maternity and newborn care
  • Mental health and substance use disorder services
  • Prescription Drugs
  • Rehabilitative and Habilitative services and devices
  • Laboratory services
  • Preventative, wellness, and chronic disease management services
  • Pediatric services, including oral and vision care

Furthermore, the out-of-pocket maximum for 2015 cannot exceed $6,600 for Individual Coverage and $13,200 for family. Your plan may NOT have a preexisting condition clause.

One final reminder: If you offer an HRA or an FSA, the HRA cannot reimburse for individual health insurance policies. FSA allowances have been adjusted for inflation such that the maximum allowed for health reimbursement accounts is $2,500.

Additional ISM resources:
ISM Monthly Update for Risk Managers Vol. 3 No. 8 Understanding the Affordable Care Act (ACA)
ISM Monthly Update for Business Officers Vol. 13 No. 1 Ask ISM's Health Care Reform Specialist "Dropping School Insurance for Individual?"
Private School News Vol. 12 No. 7 How the Health Care Reform Is Affecting Educators—And Students

Additional ISM resources for Gold Consortium members:
I&P Vol. 35 No. 7 Health Care Reform: What Schools Need to Know Now

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