Employee Benefits Compliance, Employer Mandate

UPDATE: Non-Calendar Year Health Plans Delayed Effective Date Worksheet

Do I qualify for the delayed effective date for the Employer Shared Responsibility Requirements under PPACA?

Some, but not all, large employers with non-calendar year plans may start complying with Employer Shared Responsibility provisions the first day of the 2015 plan year (rather than January 1, 2015) if certain conditions are met:

  • The employer must have maintained a non-calendar year plan as of December 27, 2012 and has not modified the plan year since then, and
  • The employer (needs to qualify for at least one of the four options):
    • Offered coverage to at least 1/3 of ALL employees, at last open enrollment before Feb. 9, 2014
    • Actually covered at least 1/4 of ALL employees, as of any day (your choice) between February 10, 2013 and February 9, 2014
    • Offered coverage to at least 1/2 of ALL FT employees, at last open enrollment before Feb. 9, 2014
    • Actually covered at least 1/3 of ALL FT employees, as of any day (your choice) between February 10, 2013 and February 9, 2014
  • As of the first day of the 2015 plan year, the employer offers affordable, minimum value coverage to at least 70% of its full-time employees.

To determine whether you qualify, complete the following worksheet. Keep a copy in your file and send a copy to your Leavitt Benefits Account Manager. Following this worksheet is a more detailed explanation of:

  1. the transition rule that allows the delayed effective date, and
  2. the potential penalties on non-compliant large employers.

Click Here for the Whole Worksheet:  Non-Calendar Year Worksheet Leavitt 5-20-15

This article updates the prior version from December 2014.