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3│ ACA R
EVIEW
Updated December 2016
Other existing nondiscrimination-type rules still enforced include:
Title VII of the Civil Rights Act of 1964 (enforced byEEOC)
Executive Order 11246 prohibits discrimination in employment by covered contractors (enforced by DOL’s
Office of Federal Contract Compliance Programs (OFCCP)
ACA Cost-Sharing Restrictions:
Out-of-Pocket (OOP) Limits
(Deductibles, Co-insurance and Co-payments)
ACA Cost-Share Restriction Reminders
Individual OOP Limit Applies to Family Maximum Limit
•
Beginning Jan. 1, 2016, an individual cannot be subject to more than the individual statutory OOP
limit on essential health benefits, even if covered by family plan
•
Two separate cost-sharing limits for different benefits permissible
Example
: one for
comprehensive medical plan; one for prescription drug plan. Combined cost share cannot
exceed the overalllimit
HSA-Embedded Deductible
•
Embedded deductible can be no lower than family statutory limit
ACA Fee Reminders:
Transitional Reinsurance Reporting and Collection of Fees (2016 Final Year) Submit annual enrollment
count and schedule one or two contribution payment dates by Nov. 15, 2016:
•
Full contribution ($27 per covered life) due by Jan. 17, 2017
OR
•
Two-part contribution:
o
Part 1 payment ($21.60 per covered life) due by Jan. 17, 2017
o
Part 2 payment ($5.40 per covered life) due by Nov. 15, 2017
Patient-Centered Outcomes Research Institute (PCORI) Fees
•
For policy and plan years ending between Oct. 1, 2016, and Oct. 1, 2017, PCORI fee will be
$2.26 multiplied by number of covered lives under policy or plan
•
PCORI fees paid annually via IRS Form 720 (generally due July 31)
Suspended ACA Fees
Cadillac tax suspended until 2020
Health insurance provider fee suspended in 2017
Excise tax on medical devices suspended for sales made Jan. 1, 2016, through Dec. 31, 2017
INDIVIDUAL/SELF-ONLY
COVERAGE
FAMILY/COVERAGE
FOR > ONE
ACA Plans*
$6,850 (for 2016)
$7,150 (for 2017)
$7,350
(proposed for 2018)
$13,700 (for 2016)
$14,300 (for 2017)
$14,700 (
proposed for 2018)
High-Deductible Health Plan
(HDHP) used with Health
Savings Account (HSA)
$6,550
(for both 2016 and 2017)
$13,100
(for both 2016 and 2017)
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