Clarification, Please...

NWBenefitProvider

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So, with the Employer Mandate delayed until 2015, that leaves me with a few questions:

1) Will employers who already offer affordable coverage have to make it available to employees who work just 30 hrs per week instead of 40, come Jan 1st, 2014? In other words, even though they do not have to provide coverage, IF they provide it does it have to be offered to 30 hr per week employees? I have several small / large groups that have eligibility set at 32-40 hrs per week and want to make sure I know their options.

2) My understanding is that come Jan 1st, 2014 waiting periods can no longer exceed 90 days. This provision remains in effect, since it encompasses both large and small groups, correct?

I'm just trying to freshen up on this, since it is changing so rapidly.

Thanks.
 
So, with the Employer Mandate delayed until 2015, that leaves me with a few questions:

1) Will employers who already offer affordable coverage have to make it available to employees who work just 30 hrs per week instead of 40, come Jan 1st, 2014? In other words, even though they do not have to provide coverage, IF they provide it does it have to be offered to 30 hr per week employees? I have several small / large groups that have eligibility set at 32-40 hrs per week and want to make sure I know their options.

2) My understanding is that come Jan 1st, 2014 waiting periods can no longer exceed 90 days. This provision remains in effect, since it encompasses both large and small groups, correct?

I'm just trying to freshen up on this, since it is changing so rapidly.

Thanks.

Yes.

Yes. And remember that 90 days is 90 days, not 3 months.

The provisions are still in effect, all that has been delayed are penalties. It's poorly thought out, but it's still the reality. And, it technically should keep people for receiving subsidies.
 
I just got back from an Anthem Blue Cross meeting. They are automatically changing small groups to a 60 day elimination period starting 1/1/14. Large groups will be changed at renewal. I would imagine that other carriers are probably going to do the same.
 
The definition of full time employment as a 30 hour work week applies only to large employers for the purpose of counting employees and for the purpose of calculating an Employer Shared Risk (play or pay) penalty. Those penalties have now been delayed.

So an employer MUST use 30 hours to see if the have 50 or more employees.

And a large employer MAY wish to adjust the definition of eligibility in its insurance contract to 30 hours if that employer's strategy is to avoid penalties by paying for insurance for more people.

Small employers are not subject to play or pay penalties and therefore probably won't adjust their insurance contract's definition of full time to 30 hours.

As for the 90 day waiting period, it is exactly 90 days, not 3 months, and not the first of the month following 90 days. So most employers will use first of the month following 60 days (or less). This applies to small and large employers.
 

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