October 1, 2013 ACA Notice Requirements for Employers
Confusion reigns regarding the Patient Protection and Affordable Care Act ("PPACA") and obligations to provide notices to employees of information regarding the new Health Insurance Market Place ("Exchanges") by no later than October 1, 2013.
WIB has received numerous calls and inquiries concerning the October 1, deadline over the past several days. Understandably, some of the requirements of the PPACA get lost in the myriad of news reports and debates about extending time limits and attacks on program funding.
WIB is therefore publishing an article by Andy DeClercq with links to model notices. Andy is an attorney with Boardman & Clark, LLP - the law firm retained by WIB to assist WIB members.
In the meantime, a couple of key issues include:
Number of Employees: The October 1, 2013 Notice Deadline is not limited to employers with more than 50 employees. The Notice requirement applies to all employers covered by the Fair Labor Standards Act ("FLSA"). The FLSA covers all employers with at least one employee and at least $500,000 annual business revenue.
Employer Coverage: The October 1, 2013 Notice Deadline is applicable whether or not the employer offers any health insurance to its employees. The model notices used will be different for employers offering health plans from those who do not.
Full vs. Part-Time Employees: The Notice requirements are applicable to both full and part-time employees.
New Hires: Employees hired after October 1, 2013, must be provided applicable notices at the time of hire or within 14 days thereafter.
COBRA Notices: Required COBRA notices for employees have been modified to reflect information on the exchanges.
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The SHOP Marketplace in Open
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Health Insurance Open Enrollment Deadline Coming
Insurance Commissioner Ted Nickel is reminding consumers that there are two Affordable Care Act (ACA) deadlines coming in the next several weeks.
The first deadline is March 15, 2014. In order to have health insurance coverage effective by April 1, 2014, consumers must have their insurance applications completed and submitted to the federal exchange by Saturday, March 15, 2014. Applications can be completed in the following ways:
- Work with a local insurance agent
- Contact a navigator or certified application counselor (for a complete list visit oci.wi.gov)
- Visit the federal Web site, www.healthcare.gov
- Call 1-800-318-2596 to speak to an exchange official
The second deadline is March 31, 2014, which is when ACA open enrollment ends. Health insurance applications submitted between March 16, 2014, and March 31, 2014, will have an effective date of May 1, 2014. If you don't enroll by March 31, 2014, you may not be able to purchase private health insurance until the next open enrollment period starts. The only way you can buy a health plan outside open enrollment is if you qualify for a special enrollment period. The next open enrollment period will be November 15, 2014, to February 15, 2015.
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