Don't miss this important Affordable Care Act deadline
The Patient Protection and Affordable Care Act—informally known as ObamaCare—is finally here, with its first major deadline for you. That’s right, Tuesday, Oct. 1, most employers in the United States will need to have provided notice to employees regarding their new increased access to affordable healthcare coverage. Several of these provisions relate to insurance coverage that will be offered through state-based health insurance marketplaces. These are being referred to as the “Exchange.”
This requirement, however, has generated much confusion and concern. Below are answers to some frequently asked questions regarding these notices:
Which employers are required to provide this notice?
You are required to provide this notice if you have at least one employee and annual gross revenue of $500,000 or more.
What if the veterinary practice has one or more employees but gross revenue is borderline? Should the practice still provide notice?
Does the veterinary practice need to provide this notice to all employees or just ones eligible for the insurance plan?
You are required to provide notice to all employees, whether or not you provide a group insurance plan, whether or not all the employees are eligible for this plan and whether or not these employees are full- or part-time.
What about new employees?
If the employee is working for you as of Oct. 1, 2013, the notice must be given no later than Oct. 1. For new employees hired after Oct. 1, the notice must be given within 14 days of hiring.
Can the veterinary practice’s insurance company provide the notice?
Yes, if the notice is provided to all employees. If certain employees are not given this notice, such as those who do not qualify for—or opt out of—the group plan, then you will not be in compliance.
What should the notice say?
The notice must include the following:
1. The existence of the Exchange.
2. A description of the services provided by the Exchange.
3. How to contact the Exchange to request assistance.
4. The employee’s potential eligibility for subsidized coverage on the Exchange if your veterinary practice’s group health plan doesn’t provide “minimum value” (i.e., the plan’s share of the total allowed costs of benefits provided under the plan is less than 60 percent of such costs).
5. The fact that the employee may lose the employer contribution toward health insurance coverage if he or she chooses to purchase individual coverage on the Exchange.
Are there examples of these notices?
Yes. The Department of Labor has written examples that satisfy the statute's requirements. You are not required to use these specific notices as long as the one you use covers the above requirements.
The first notice is for employers who offer a health plan to some or all employees. Download it here.
The second notice is for employers who do not offer a health plan. Download it here
There is also a Spanish version for each of these notices at the website.
The Department of Labor notice for employers who offer some sort of health insurance coverage has both a Part A and a Part B. What do we need to fill out?
You need to fill out information on both Part A and Part B.
Part A contains standard information about the Exchange. Complete the blank line at the bottom.
Part B requires more information. Questions 13-16 on page 3 are optional.
The Department of Labor notice for employers who offer no health insurance coverage also has a Part A and Part B. What do we need to fill out?
You don’t have to complete anything on Part A, but Part B requires specific information you need to fill out.
How should we deliver these notices to our employees?
The Department of Labor recommends delivery by first class mail. There are email options available, but the requirements are tricky and convoluted so we recommend delivery by first class mail.