Employers Cannot Ignore other ACA Provisions
Even with the delay in the employer mandate and reporting requirements, employers cannot ignore other provisions of the ACA that have become effective already or will become effective in 2014. These include the following:
90-Day Waiting Periods Limit : Effective for plan years beginning on or after January 1, 2014, a group health plan or health insurance issuer cannot impose any waiting period that exceeds 90 days.
Maximum Out-of-Pocket Limitation : Effective for plan years beginning on or after January 1, 2014, group health plan must comply with a new maximum out-of-pocket limitation, which is $6,350 for employee-only coverage and $12,700 for family coverage. There is limited transition relief for plans and issuers that use more than one service provider to administer benefits that are subject to the annual limit. This requirement applies to both self-funded and insured plans.
Patient-Centered Outcomes Research Institute (PCORI) Fee: Health insurance issuers and sponsors self-funded plans must pay a fee to fund the patient-centered outcomes and research institute based on the average numbers of lives covered. The PCORI fee is $2 ($1 in the case of a policy or plan year ending before October 1, 2013, and $2 for subsequent years). The fee expires in 2019.
Transitional Reinsurance Fee : Insured and self-funded plans must pay a per enrollee fee of $63. The number of enrollees must be reported by November 15, 2014. The first fee must be paid in early 2015.
Preexisting Condition Exclusions: Effective for plan years beginning on or after January 1, 2014, the prohibition on preexisting condition exclusions (currently applicable only with respect to individual under age 19) is extended to individuals of all ages.
Elimination of Annual Limits: Effective for plan years beginning on or after January 1, 2014, annual limits on the dollar amount of essential health benefits are prohibited.