Model Notice Informs Employees of Eligibility for Premium Assistance Under Medicaid or CHIP

The U.S. Department of Labor (DOL) has updated its model notice for employers to provide information on eligibility for premium assistance under Medicaid or the Children’s Health Insurance Program (CHIP). This notice is generally updated twice a year. Click here to download the updated notice in PDF format.

Annual Notice Requirement
Employers that provide health insurance coverage in states with premium assistance through Medicaid or CHIP must provide employees with the employer CHIP notice annually before the start of each plan year. An employer can choose to provide the notice on its own or concurrent with the furnishing of:

• Materials notifying the employee of health plan eligibility;
• Materials provided to the employee in connection with an open season or election process conducted under the plan; or
• The summary plan description (SPD).

The updated model notice includes information on how employees can contact their state for additional information and how to apply for premium assistance, with information current as of July 31, 2018.

Our Benefits Notices by Company Size section features information on additional health plan notice requirements.

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New Rule Loosens Current Restrictions

Effective October 3, 2018, a new rule will allow individuals to purchase short-term, limited-duration health insurance coverage for a period of less than 12 months, and renew such coverage for up to 36 months. Under current law, the maximum coverage period for short-term, limited-duration health insurance is less than 3 months, and these policies cannot be renewed.

Notably, short-term, limited-duration health insurance is:

• Not required to comply with the Affordable Care Act’s ban on pre-existing condition exclusions and lifetime and annual dollar limits.
• Not required to comply with the Affordable Care Act’s essential health benefits requirement, which requires individual health insurance policies to cover, among other things, hospitalizations, emergency services, and maternity care.
• Not “minimum essential coverage,” meaning that policyholders may remain liable for an individual mandate penalty for any month in 2018.

Click here to read the new rule. A fact sheet is also available.

Check out our Health Care Reform section for more on the Affordable Care Act.

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Health Care Reform Updates provided by:

Team Nash
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385-234-6754

Please Note: The information and materials herein are provided for general information purposes only and are not intended to constitute legal or other advice or opinions on any specific matters and are not intended to replace the advice of a qualified attorney, plan provider or other professional advisor. This information has been taken from sources which we believe to be reliable, but there is no guarantee as to its accuracy. In accordance with IRS Circular 230, this communication is not intended or written to be used, and cannot be used as or considered a ‘covered opinion’ or other written tax advice and should not be relied upon for any purpose other than its intended purpose.

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Various federal workplace poster requirements apply to employers across the United States. This Federal Workplace Poster Requirements chart includes helpful information and links to download the following posters:

• Minimum Wage Posters
• OSHA Posters
• FMLA Posters
• Workers with Disabilities Posters

Click on the image below to download the chart.

The federal Occupational Safety and Health Administration (OSHA) recently announced that covered establishments in all states-including establishments in California, Maryland, Minnesota, South Carolina, Utah, Washington, and Wyoming-must electronically submit data from their 2017 OSHA Form 300A to OSHA by July 1, 2018. Previously, employers in those seven states were deemed exempt.

As a reminder, the following establishments-if currently required to comply with OSHA’s recordkeeping requirements-are required to electronically submit data from their 2017 Forms 300A to OSHA:

• Establishments with 250 or more employees; and
• Establishments in certain designated industries with 20-249 employees.

Click here to read the OSHA announcement. To submit your establishment’s data, click here.

To learn more, check out our Electronic Recordkeeping Requirementpage.

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Policies Renewed Under Extended Transitional Policy Must End by December 31, 2019

A previously extended transitional policy which allows health insurance issuers, at their option, to continue group coverage that would otherwise be terminated or cancelled has been further extended to policy years beginning on or before October 1, 2019, provided that all policies end by December 31, 2019. Health insurance issuers that renew coverage under the extended policy are required to provide standard notices to affected small businesses for each policy year.

Policies subject to the transitional relief will not be considered to be out of compliance with key Affordable Care Act provisions, including:

• The requirement to cover a core package of items and services known as essential health benefits;
• The requirement that any variations in premiums be limited with regard to a particular plan or coverage to age, tobacco use, family size, and geography;
• The requirements regarding guaranteed availability and renewability of coverage; and
• The requirements relating to coverage for individuals participating in approved clinical trials.

Click here to review the extended transitional policy.

Visit our ACA by Year & Company Size section for an overview of other requirements related to Health Care Reform.

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Health Care Reform Updates

by Team Nash

HHS Issues Key Rule for 2019

A new rule from the U.S. Department of Health and Human Services (HHS) addresses, among other things, the requirement under the Affordable Care Act that non-grandfathered group health plans limit annual out-of-pocket cost-sharing for coverage of essential health benefits under the plan. Under the rule, these out-of-pocket expenses may not exceed $7,900 for self-only coverage or $15,800 for family coverage in 2019.

Please visit our Health Care Reform section for other employer requirements.

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