October 2012 Health Care Reform
Posted on: October 3, 2012Categories: HR & ComplianceDetermining Minimum Value
On August 31, 2012, the IRS issued Notice 2012-59 in conjunction with the DOL and HHS to provide temporary guidance on the 90 day waiting period limit. The temporary guidance will remain in effect at least through the end of 2014. According to Notice 2012-59, if more guidance is issued on the 90-day waiting period limit for periods after 2014, plans and issuers will be given adequate time to comply with any additional or modified requirements. For employers to fall into the large group category they must employ an average of at least 50 full-time employees during their prior calendar year.
IRS Notice 2012-31 focuses on determining minimum plan value. According to the ACA in order for a plan to provide minimum plan value then it must share a total of 60% of total allowed costs of benefits offered under the plan. The IRS gives three possible determining factors that we can use to determine whether or not a group plan does indeed provide minimum value. The first factor is an actuarial value calculator or a minimum value calculator. The second factor is a checklist which is an easier means to determine whether a plan provides minimum value without using a calculator or performing any calculations and without the need for actuarial expertise. The final factor is actuarial certification. This could be used for plans with “non-standard features”. IRS Notice 2012-32 pertains to the actual reporting of minimum essential coverage. IRS Notice 2012-33 centers around reporting for large groups. See below for all of these IRS notification and additional legislative briefs on these rulings.
Additional Resources:
Click here to view the legislative brief on the 90 Day Waiting Period
Click here to view the legislative brief on Determining Minimum Value
Click here to view Notice 2012-31 from the IRS website
Click here to view Notice 2012-32 from the IRS website
Click here to view Notice 2012-33 from the IRS website
Click here to view Notice 2012-58 from the IRS website
Click here to view Notice 2012-59 from the IRS website
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