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Blog By: Beth Ede, SPHR

When the Affordable Care Act was passed in March of 2010, January 1, 2014 loomed large as the date when many of the major changes brought about by health care reform would take effect. 


As we have approached specific effective dates, we have seen the various parts not always fitting together smoothly.  The responsible parties and the Obama Administration have been scrambling to fix problems and keep us moving forward on the health care reform path.


If you are challenged in keeping up with the ACA developments, you are certainly not alone.  To help sort it out a bit, here are a few recent developments to be aware of:


§  Large employer “Play or Pay” fees have been delayed a year – from 2014 to 2015.

§  Federally-facilitated (FF) SHOP exchange plans will not be available until 2015.  Small employers in FF states will need to use direct enrollment in SHOP plans through an agent, broker, or insurer.  This will allow small employers to still take advantage of the Small Business Health Care Tax Credit available to them.

§  Self-funded, self-administered health plans will not be subject to the reinsurance fee for 2015 & 2016 based on a proposal by HHS

§  Some insured plans that would otherwise have been cancelled due to not meeting ACA’s minimum requirements could remain in force.  Individual states will be making this decision (MN – scheduled plans will remain cancelled; WI – will allow plans to be reinstated).

§  IRS has relaxed the “use-or-lose” rule for health FSAs – allowing for up to a $500 carryover of unused funds, but only for plans that don’t include a grace period.

§  Employers that offer a non-year cafeteria plan may allow participants to make a mid-year election change for the 2013 plan year due to ACA developments for 2014.


As we move into 2014 and beyond, keep in mind that large employers (50 or more full-time and full-time equivalent employees) need to put plans in place and take action throughout 2014 on “Play or Pay” requirements.  Even with some unanswered questions and while awaiting further guidance, move your plans forward in preparation for compliance in 2015.


As we move forward, all of us affected by ACA will continue to face challenges – like keeping up on the latest developments, figuring out what the requirements mean, and making decisions with limited information and guidance.


Remember to keep health care reform compliance focused on your radar.  If WA can be of further assistance to you, please feel free to contact us.


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