Until proposed ACA Repeal and Replace legislation is passed, it's business as usual. To prepare for open enrollment, school, city and county employers need to be aware of the 2017 Affordable Care Act (ACA) changes which will affect their plans for the plan years beginning on or after January 1, 2017. These changes may affect the design and administration of your plans. Below is a brief overview of some of the changes. For more details, download the 2017 Open Enrollment Checklist.
Plan Design Issues
2017 ACA changes include some new compliance guidelines, changes to certain annual limits and other rules.
- Check to see if your plan’s out-of-pocket maximum comply with the ACA 2017 limits.
- If you have a HDHP (high deductible health plan), does your out-of-pocket maximum and deductible comply with the 2017 limits?
- If your wellness program includes a health risk assessment, make sure that you are compliant under the new EEOC (Equal Employment Opportunity Commission) rules
ACA Disclosure Requirements
School, City and County employers should ensure employees receive a summary of benefits and coverage (SBC). This document helps them understand their coverage and make coverage decisions. For fully insured groups, your health insurance carrier should be providing this summary. If you are self-insured, check with your 3rd party administrator to see if they will be providing it or if the task falls onto you.
Note that the SBC must be provided to employees who enroll or re-enroll during an open enrollment period or are newly eligible for coverage. Effective April 1, 2017, you must use the new template issued by the Departments of Labor, Health and Human Services and the Treasury during your open enrollment period or plan years beginning on or after April 1, 2017. A link to this new template can be found in the 2017 Open Enrollment Checklist.
Additional Notices for School, City and County Employers
Employers can include additional enrollment and annual notices during the open enrollment period, notifying employees about their rights in regards to HIPAA, COBRA, WHCRA (Women’s Health and Cancer Rights Act), Medicare Part D and more. There are certain notices that new hires need to receive within 90 days after the plan coverage begins. Some notices need to be provided on an annual basis to all employees. Other notices may need to be provided periodically (like every three, five or ten years, depending on the notice). Model language for some of these notices can be found in the 2017 Open Enrollment Checklist.
