Some employers may believe that because the employer mandate provision of the Affordable Care Act (ACA) has been delayed until January 1, 2015, they face no new requirements under the law until that date.
While large companies (over 50 full-time employees) have been given an extra year (until 1/1/15) to provide health insurance to their employees, employers are still required under ACA to notify employees about their options for health insurance.
Notification MUST be provided to every employee no later than OCTOBER 1, 2013. New employees hired after October 1 must receive their notification within 14 days of being hired.
Click here to access our earlier posts about this important requirement.
Haven’t prepared your notices yet? Here are a few key points for business owners to keep in mind:
Who must receive the notice?
Notice of coverage options must go to every employee, regardless of whether or not the employee participates in a group plan and regardless of the employee’s full-time/part-time status. It must go to union employees and those in benefit waiting periods. Dependents or other participants in your company’s group coverage who are not current employees, as well as former employees (including those on COBRA), do not need to be notified.
Employees hired after October 1, 2013 must be notified within 14 days of hire date.
How should the exchange notice be distributed?
It must be provided, in writing, to each employee. Here are some examples of acceptable methods of distribution:
- Mail via first-class mail
- Distribute electronically (must adhere to Department of Labor’s guidelines for electronic disclosure)
- Include in benefits renewal packets – but be sure the packet goes to all employees
- Include with new hire kits for those hired after October 1, 2013
- Personally hand out to each employee (it is not ok, for example, to leave a stack out in a common area; each employee must personally receive the letter)
- Attach to paychecks
Is there a template I can follow?
Yes. The Department of Labor has released model letters. Although your notice does not need to follow the model verbatim, it must include certain information. Click here to learn more.
Does my company’s compliance with the notice requirement need to be documented?
Although there is no specific requirement for documentation, we recommend that employers keep a copy of the notice, along with a list of how it was distributed, to whom it was provided, and the date(s) it was provided to each employee.
We do not provide health insurance for our employees. Do we still need to send the notices?
Yes. All employers must provide notification!
Is there anything else I should do?
The notices are likely to generate questions from your employees. We recommend you designate a company representative to handle any inquiries. For our business customers, Virginia Medical Plans can also arrange to meet with your employees to help answer any questions they may have.
If you are a business owner and have not yet prepared your notices, don’t delay! Give us a call if we can be of assistance!