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Posted on NOV 3, 2016

Health care reform update: impending deadlines and 2017 requirements

A new year is just around the corner. While you may feel as if you've only just wrapped your head around the 2016 health care law requirements and deadlines, now is a good time to look ahead to 2017. “The Affordable Care Act (ACA) has numerous rules employers must follow, many of which can be downright confusing,” says Maureen Lawson, VP, Employee Benefits Compliance and Capabilities, Johnson Insurance.“

Adding to the confusion is the fact that some of these regulations, such as health insurance out‐of‐pocket maximums, are subject to change, requiring employers who provide insurance to more effectively work with their insurance advisor to remain compliant.

With some planning, however, it's possible to be prepared for the new requirements and deadlines in 2017. Below are some of the important deadlines you should mark on your calendar.

At a Glance: Impending Deadlines to Consider

  • November 15, 2016 – ACA Transitional Reinsurance Program Annual Enrollment and Contributions Submission Form due.
  • January 31, 2017 – ACA forms 1095‐B and 1095‐C due to employees.
  • February 28, 2017 – ACA forms 1094‐B, 1095‐B, 1094‐C and 1095‐C due to the IRS if filing by mail.
  • March 31, 2017 – ACA forms 1094‐B, 1095‐B, 1094‐C and 1095‐C due to the IRS if filing electronically.
  • Annually – CHIPRA (Children's Health Insurance Program Reauthorization Act) notice of premium assistance.
  • Every three years – HIPAA privacy notice required to be distributed.

In‐Depth: Employee Benefit Plan Requirements and Changes for 2017

ACA Out‐of‐Pocket Maximums.

To comply with the ACA, your plan's out‐of‐pocket maximum must not exceed $7,150 for self‐only coverage, and $14,300 for family coverage. “Out‐of‐pocket maximums can change every year, so it's a good idea to review your plan with an advisor now to be certain that it's in compliance,” Lawson says.

Health Savings Account (HSA) High Deductible Health Plan (HDHP) Out‐of‐Pocket Requirements.

It's important to remember that the out‐of‐pocket requirements for HSA high deductible plans are lower than the ACA's requirements. The out‐of‐pocket maximum limit for HDHPs remains unchanged from 2016 at $6,550 for self‐only coverage and $13,100 for family coverage.

Summary of Benefits and Coverage (SBC) Changes.

Last April, the departments of Health and Human Services, Treasury, and Labor announced key enhancements to the SBC template and the Uniform Glossary. The changes include an additional coverage example and language, as well as terms to help improve consumers' understanding of their health coverage. The Centers for Medicare and Medicaid Services offers a sample of a completed SBC form, which is typically used as the standard.

ACA Information Reporting Deadline.

The deadline for ACA information reporting will be earlier than previous deadlines. “In 2016, employers received some relief as the IRS extended the employee notification and IRS filing deadline for reporting on tax year 2015,” says Lawson. “The IRS has indicated that no such extensions will be made in 2017 for reporting on tax year 2016. Employers should make note of the new deadlines because they come up quickly.” Key upcoming ACA form deadlines are noted in the “at a glance” section above.

Helping You Make Sense of It All

At Johnson Insurance, it's our goal to help you navigate the complex world of health care law and employee benefit regulations. For more information on upcoming health care reform requirements and deadlines, contact your Johnson Insurance advisor.

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