Seven ACA Compliance Reminders for 2018
Going into 2018, the Affordable Care Act (ACA) remains the law. This means that staying compliant is as important as ever. However, don’t assume what you did in 2017 will work in 2018. Use these seven ACA compliance reminders as a starting point for your 2018 preparations.
- Summary of Benefits and Coverage: Employers must provide a document that details the health plan in a way that is clear and consistent. The DOL provides information about the Summary of Benefits and Coverage, including a template.
- Employer shared responsibility: Applicable large employers (ALEs) must provide affordable coverage with minimum essential value to full-time employees and their dependents or face penalties. Whether an employer qualifies as an ALE in 2018 depends on the size of the workforce in 2017. The Employer Shared Responsibility Provision Estimator helps employers determine whether they are ALEs and the maximum potential liability for failing to offer coverage to full-time employees.
- Out-of-pocket maximums: Starting on January 1, 2018, the out-of-pocket maximum for essential health benefits is $7,350 for self-only individual coverage and $14,700 for family coverage. This is an increase from the previous year.
- High deductible health plan definitions: For 2018, a self-only high deductible health plan has an annual deductible that is not less than $1,350 and out-of-pocket expenses that are not more than $6,650. For family coverage, the annual deductible is not less than $2,700 and the out of-pocket expenses are not more than $13,300.
- HSA contribution limits: For 2018, the annual limitation on deductions for an individual with self-only coverage with a high deductible health plan is $3,450. With family coverage, the annual limitation on deductions is $6,900.
- Reporting requirements: The ACA includes reporting requirements for ALEs under codes 6055 and 6056. Key forms include 1094-B, 1095-B, 1094-C and 1095-C. Instructions for 1094-B and 1095-B are available here, and instructions for 1094-C and 1095-C are available here. Reporting on 2017 will be due in early 2018.
- Status as a grandfathered plan: Think your plan’s exempt from some requirements because it was grandfathered in? Be careful. For plans that were grandfathered in, making certain changes can cause the plan to lose its grandfathered status. Specifically, job-based grandfathered plans can maintain their grandfathered status if they have not had benefits cuts substantially or costs increased for plan holders and they have covered at least one person continuously since March 23, 2010. Additionally, plan holders must be notified of the plan’s grandfathered status.
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