The NCMS Plan has been engaged in studying the implications of the Affordable Care Act (ACA) since it became law in 2010. We are prepared when our participating practices need answers to questions on the impact to their employee benefit plans. Click here to learn why the NCMS Plan is the alternative of choice for medical practices confused by Health Care Reform. You may find this Health Care Reform Employer Checklist useful as both a refresher on applicable ACA requirements and how they impact the NCMS Plan and your practice. From a strategic perspective, our approach is three-fold: •Stay current and access varied sources of information on the requirements of the legislation; •Bring disciplined debate to the interpretation of the statutes and how they apply to the NCMS Plan, •Bring credible, actionable information and advice to NCMS Plan clients. We conducted a webinar exclusively for NCMS Plan practices in partnership with Spilman, Thomas & Battle, a law firm with attorneys specializing in Labor & Employment law; and Elkin & Associates, a prominent third party administrator in Charlotte specializing in Flexible Benefit Plan design and management. NCMS Plan practices can access a recording of this webinar from June 6, 2013. This presentation is based on the most recent information and guidance available at the time. The ACA will apply differently to different employers based on their specific circumstances. Employers should consult their attorney or tax advisor for questions beyond the application of the ACA to the NCMS Plan and its employee benefit programs. Looking for help when it comes to navigating Health Care Reform and building a health care and employee benefits strategy that supports your business objectives? Let us help. Contact your NCMS Plan agent or call us today at 800-662-7917.


Forms 1094 and 1095: A requirement of the ACA is that employers report to the IRS and their enrolled employees information about health coverage provided. This is due to the individual coverage mandate and the employer shared responsibility mandate. The reporting requirement begins with tax year 2015 with the first forms due in early 2016. NCMS Plan practices are not fully-insured employers, rather they are employers sponsoring a self-funded multiple employer welfare arrangement (MEWA). As such, participating practices are required to file information with the IRS regarding coverage provided and to furnish statements to covered individuals regarding their minimum essential coverage. The NCMS Plan is not responsible for this reporting on behalf of participating practices. A MEWA should not be confused with a “Multiemployer Plan”, a term that is frequently used in IRS communications regarding ACA reporting requirements. A multiemployer plan is an employee benefit plan maintained under one or more collective bargaining agreements to which more than one employer contributes. These collective bargaining agreements typically involve one or more local unions that are part of the same national or international labor union and more than one employer. The NCMS Plan is not a multiemployer plan. The forms that a practice would complete are 1) the 1095, which is sent to both the individual on a policy and the IRS, and 2) the 1094, a cover sheet sent to the IRS that accompanies the 1095s. Depending on the size of your practice (more than or less than 50 full-time equivalents), you may need to file the B (less than 50) or the C (more than 50) form. The C form requires more information including the cost of coverage to the enrolled employee. The 1094 and 1095 forms for tax year 2015 have not yet been published by the IRS. However the instructions for the 2014 B forms and the 2014 C forms may serve as an early guide to what is likely to be expected for 2015. Most NCMS Plan practices (those with less than 50 full-time equivalents) will complete 1094-B and 1095-B. Though the 1094/95-Bs are subject to change when 2015 forms are finalized, the coverage your practice is offering to employees is employer-sponsored coverage (Part I, Line 8). Since you are reporting self-insured group coverage you will not complete Part II (Lines 10-15). As the sponsoring employer, you will enter your practice’s name and information in Part III. In Part IV, you will enter information for each covered individual. Larger NCMS Plan practices subject to the employer shared responsibility mandate will report information about coverage on Form 1095-C. Practices with third-party payroll services or human resource information systems should consult their vendors to see if their systems will facilitate this reporting on your behalf. The ACA and its reporting requirements can be confusing and this is only a brief summary. More information regarding these reporting requirements can be found on the IRS website, but if you have questions, please contact your NCMS Plan agent or our office at (800) 662-7917.


Actuarial Value information: The ACA establishes four levels of coverage based on the concept of “actuarial value,” which represents the share of health care expenses a plan covers for a typical group of enrollees. As plans increase in actuarial value – bronze, silver, gold, and platinum – they would cover a greater share of enrollees’ medical expenses overall, though the details could vary across plans. Since NCMS Plan coverage is available exclusively outside the Exchange, the metal-tier plan levels are not relevant.


 

Important Health Care Reform Update (July 2, 2013): Key provision delayed until January 1, 2015. The government will postpone enforcement of the employer mandate until 2015. Under this provision, companies with 50 or more workers face a fine of as much as $3,000 per employee if they do not offer affordable insurance.