Benefits, Employer Mandate, Health Care Reform, HIPAA, Reporting & Disclosure, Reporting Requirements

Reminder: Imminent Deadlines & Updated Amounts

Just a quick reminder about some imminent deadlines and updated dollar amounts. We have posted separate articles on various topics, as well as a Q1 Deadlines and Reminders, but this one page is a quick summary of relevant topics as of February 27, 2017.

  • February 28—Information reporting. If you are NOT filing electronically, your paper forms 1094-C and 1095-C are due to the IRS by tomorrow, February 28th. Employers can file paper forms if they file fewer than 250 of any type of form, or can elect instead to file electronically even if not required to. “Applicable large employers” (ALEs) file forms 1094-C and 1095-C. Small employers with self-insured plans must file forms 1094-B and 1095-B.  NOTE: Date to file 1094 and 1095 series forms electronically is March 31st.
  • March 1 or Earlier— Medicare Part D. Employers with calendar year group health plans who offer prescription drug coverage to individuals who are eligible for Medicare must go online and complete the Medicare Part D Online Disclosure to CMS of Creditable Coverage Status. This is at: https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/ CCDisclosureForm.html (The deadline is within 60 days after first day of plan year. Non-calendar year plan should determine applicable date.)
  • March 1— PHI Breach. If you had a breach of protected health information (PHI) during 2016 and it involved the PHI of fewer than 500 individuals, this is the date by which the Office for Civil Rights (OCR) must be notified. Covered entities (such as group health plans) must track any breaches of unsecured PHI in a log, and that must be submitted to OCR within 60 days after the end of each calendar year. (If you had a breach that involved PHI of 500 or more individuals, you should have notified OCR within 30 days, so you do NOT also have to submit another notification after the end of the calendar year.
  • March 1—MEWAs file Form M-1. Deadline by which multiple employer welfare arrangements (MEWAs) providing health coverage must file annual Form M-1. Form is for the prior calendar year, and must be filed electronically.
  • March 2— 1095-Cs to employees. Deadline by which applicable large employers (ALEs) must furnish 1095-Cs to all full-time employees, and if self-funded, to employees who were not full-time but who enrolled in employer group coverage at all during 2016. Small employers with self-insured plans must furnish 1095-Bs to employees who were enrolled in self-insured coverage at any time in 2016.   (This deadline originally was Jan. 31, but IRS Notice 2016-70 delayed it to March 2.)
  • March 30 and 90 days after certain Events—Summary Plan Description (SPD) must be distributed to plan participants (calendar year plans).

Updated dollar amounts:

PCORI fee:
$2.26 per enrollee, for plan or policy years ending on or after 10/1/16, and before 10/1/17.
$2.17 per enrollee for, for plan or policy years ending on or after 10/1/15, and before 10/1/16.

Employer mandate:
$97. 38 = Maximum “affordable” employee monthly cost for self-only coverage for 2017.
$12,060 = 2017 mainland Federal Poverty level (FPL) for an individual.
9.69% = 9.5% indexed. (affordability percentage)

Health FSA/H.S.A./HDHP

$2,600 = annual maximum employee pre-tax contribution to Health FSA.
$3,400 self-only/$6,750 family = H.S.A. maximum annual contribution (plus $1,000 catch –up contribution for account holders at least age 55)
$1,300 self-only/$2,600 family coverage = minimum deductibles for High Deductible Health Plans (HDHPs) that are H.S.A.-compatible.

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