Health Care Reform Rollout An Educational Seminar
TheIXG.com 1
Developing Strategy Managing Risk Realizing Your Vision
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Health Care Reform Rollout A presentation designed to educate and assist employers regarding the latest information on the new Health Care Reform laws and their implementation. 3
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Alicia Gibson Managing Partner IXG Consulting Group
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March 23, 2010
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Chapters:
Immediate Changes Quality Health Insurance for All Avenues To Obtaining Coverage Qualified Health Plans Hot Topics Critical Dates - Resources 7
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Immediate Changes 9
Immediate Changes Grandfathered Plans
Pre-Existing Conditions
Annual Lifetime Limits
Preventative Care Discriminatory Practices
Summary of Benefits
Patient Protections
Immediate Changes 10
Dependent Coverage
Rescissions
Medical Loss Ratio
Grandfathered Plans ( March 23, 2010 )
Grandfathered status will remain intact unless:
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Eliminating benefits Increasing the cost-sharing requirement Increasing a fixed-amount co-payment Certain reductions in employer or employee organization contribution rates
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Changes in annual benefit limits
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Grandfathered Plans Effect of Grandfathered Health Plan Status PPACA Provision
Application to Grandfathered Individual Health Plan
Application to Grandfathered Group Health Plan
Patient Protections
Exempt
Exempt
Pre-existing Conditions Exclusion
Exempt
Must Comply
Annual Benefit Limits
Exempt
Must Comply
Lifetime Benefit Limits
Must Comply
Must Comply
Rescission of Coverage
Must Comply
Must Comply
Immediate Changes
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Pre-Existing Conditions Coverage for age 19 years of age and younger
Individual grandfathered plans not required to comply
Rates can be based on pre-existing medical conditions
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Dependent Coverage As of September 23, 2010, health insurance coverage was extended to age 26 for dependents Dependent status is not reflective of enrollment in full-time studies
Applicable to All Plans
Immediate Changes
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Annual Limits Research shows that annual benefit limits are imposed on: 8.2% of Large Employer Plans 14.4% of Small Employer Plans 19% of Individual Plans
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Lifetime Limits Lifetime Limits Are Imposed On: 63% of Large Employer Plans 32% of Small Employer Plans 89% of Individual Plans
Immediate Changes
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Annual & Lifetime Limits * 1 in 3 adults suffer from Heart Disease * 11 Million are affected by Cancer
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Annual & Lifetime Limits
10% of cancer patients reached their limit in 2006
Exposure to 101+ million Enrollees
Immediate Changes
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Annual & Lifetime Limits Three-Year Phase out of annual limits $750,000 for plan years beginning $1.25 Million for plan years beginning $2 Million for plan years beginning
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9/23/2010 – 9/23/2011 9/23/11 – 9/23/2012 9/23/2012 – 12/31/2013
Annual Limits Implementation of unlimited coverage is to prevent the financial stress and loss of needed healthcare for serious medical conditions, leading to worsening medical conditions and potentially early death.
Immediate Changes
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Preventative Services As of September 23, 2010, grandfathered plans were not required to comply Preventative services are now covered at 100% with no cost sharing, deductible, or co-pays Patient Awareness - Involvement in Health Care Decisions
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Rescission of Benefits Average of 10,700 rescissions have occurred each year Retroactive Cancellation A plan can be rescinded anytime for fraud or intentional misrepresentation of material facts 30 day notice of rescission Immediate Changes
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Summary of Benefits ( October 1, 2012 and plan year thereafter )
Plans and plan administrators are required to distribute a standardized form that offers a summary of coverage to all enrolled.
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Discriminatory Practices This prohibits the discrimination in favor of highly compensated employees receiving “Cadillac Plans.� 40% Tax Penalty
Immediate Changes
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Medical Loss Ratio (MLR) Requires: ✴ 85% of premium dollars spent within large group market ✴ 80% of premium dollars spent within small/ individual markets ✴ To be spent on clinical services and activities that improve health care quality.
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Patient Protections •
Primary Care Providers are able to be chosen by the insured: Pediatricians and OB/GYNs are now able to be considered a PCP under plans - no referrals required
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New Laws allow insureds to obtain emergency care without prior authorization and without regard to in- or out- of network providers
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Payment from insurance will be based on in-network percentages at a reasonable rate (*not applicable to grandfathered plans)
Immediate Changes
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Quality Health Insurance for All 27
Quality Health Insurance Notification of Changes
Guaranteed Coverage
Rating Structure
Waiting Periods
Tax-Favored Plans
Quality Health Insurance 28
Exclusions
Subsidy Eligibility
Notification of Exchanges Employers are required to inform the employee of: 1. The existence of exchanges 2. Eligibility for tax credits or subsidies 3. Loss of employer contribution
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Guaranteed Coverage ✴ Every employer and every individual that applies for coverage must be accepted by the insurer
✴ Open and special enrollment periods may be implemented. IMPORTANT
Open enrollment is October, 2013 through February, 2014. “Qualifying Events”
Quality Health Insurance 30
Pre-Existing Conditions As of‌ January 1, 2014 plans may no longer impose pre-existing condition exclusions
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Rating Structure Fair Health Insurance Premiums
✴ Applicable to Small Group and Individual Plans ✴ Large Group where eligible to purchase through the Exchange Monthly Premium Based On: •
*AGE
3:1
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TOBACCO USAGE
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FAMILY MAKE-UP
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GEOGRAPHY
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ACTUARIAL VALUE OF THE BENEFIT
1.5:1
*The maximum increase in premium based on age is 3 times the cost of the lowest plan cost.
Quality Health Insurance 32
Waiting Periods Small & Large Groups
…cannot impose a waiting period over 90 days for new employees or newly eligible employees
Large Groups
✴
Auto enrollment for all employees
✴
Can still impose a wait period (Not to exceed 90 days)
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Employee has the option to waive coverage
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Subsidy Eligibility Premium Credit
Any level plan for those that fall within the 138% - 400% FPL
Cost Sharing
Available for those that fall within 138% 250% of FPL (Silver Plan Only)
Quality Health Insurance 34
Subsidy Eligibility Federal Poverty Level Chart Federal Poverty Level = $11,490 (single) Federal Poverty Level = $19,530 (for average family size of 3.13)
Below 133% Free
133%–400% Reduction
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Above 400% No Reduction
Premium Assistance Employees Offered Premium Assistance Credit
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If an employee has access to insurance through work
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and the cost exceeds 9.5% of the employee income
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and the employee is within 400% FPL
Then
The employee is eligible to a subsidy through the exchange.
Total Allowed benefit costs is less than 60% Actuarial Value.
Quality Health Insurance 36
Out of Pocket Expenses For individuals at or below 400% of the FPL, out of pocket expenses will be capped by: 2/3 if income is 100%–200% 1/2 if income is 200-300% 1/3 if income is 300-400%
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Tax-Favored Plans FSA, HSA, HRA Limits and Rules
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Flexible Spending Account - $2500
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Health Reimbursement Arrangements - No Limit - Self-Employed Individuals not eligible
Health Savings Accounts - $3100 max contribution for an individual - $6250 max contribution for a family - $1,000 for each person over the age of 55
Quality Health Insurance 38
TAX TALK
Mr. Marty Halloran, CPA mhalloran@halloranCPA.com
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TAX TALK Patient Protection & Affordable Care Act: 2013 1. Additional 0.9% Medicare tax imposed on wages, compensation or self-employed income. Threshold: Married filing joint $250,000, Married filing separate $125,000, all others $200,000.
Employers must withhold this tax when wages exceed $200,000 in the current year. There is no employer match.
2. Health flexible spending accounts will be capped at $2,500 a year
Quality Health Insurance 40
Mr. Marty Halloran, CPA
TAX TALK
mhalloran@halloranCPA.com
Patient Protection & Affordable Care Act: 2013 3. The 7.5% floor for deducting medical expenses increases to 10% for filers under age 65. 4. Unearned income will be subject to a 3.8% Medicare surtax when modified adjusted gross income exceeds the same thresholds as in #1 above. Unearned income is defined as interest, dividends, capital gains, annuities, royalties and passive rental income. Tax-free interest or retirement plan income is not included.
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TAX TALK Patient Protection & Affordable Care Act: 2014 1. Individuals who remain uninsured will owe a penalty tax equal to the larger of $95 or 1% of income above the filing threshold. For 2015 the minimum penalty is $325 and in 2016 it will be $695 or 2.5% of income above the filing threshold. 2. The family penalty is 3 times the individual amounts without regard to number of family members. 3. Impose a $2,000 per employee penalty on employers with more than 50 employees who do not offer health insurance to their full-time workers.
Quality Health Insurance 42
Mr. Marty Halloran, CPA
TAX TALK
mhalloran@halloranCPA.com
A “Cadillac Tax” is imposed on employer-sponsored health plans. 40% excise tax charged on the excess benefit of $10,200 for singleonly coverage and $27,500 for family coverage. This is total cost of insurance, not just employee paid premiums. Other Items: Small Business Health Care Tax Credit – enacted in 2010 with a maximum 35% tax credit through 2013 and expanded to 50% starting 2014. Must have less than 25 full-time equivalent employees with under a $50,000 average salary. File form 8941 with your business tax return.
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Avenues to Obtaining Coverage
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Avenues to Obtaining Coverage Federal/State Run Exchange
Shop Exchanges
Grandfathered Plans
Employer Coverage
Obtaining Coverage 46
Co-Ops, Non-Profits Member Run Plans
Medicare & Medicaid
Exchanges Exchanges Are Responsible for: Certification of Qualified Health Plans
Presenting Plans in Standard Format
Grant Exemptions from Individual Responsibility
Operation of Toll Free Phone # and Website
Eligibility of Medicare/ Medicaid
Seamless Communication Medicaid & CHIP
Rating of All Plans offered
Electronic Calculator for Plans
Online Enrollment
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Exchanges 1. Who will be able to utilize the Exchange and when? Beginning Oct 2013, open enrollment begins for Small Businesses & Individuals 2. Small Business Health Option Program - “SHOP” 3. Consumer operated & Oriented Plans - “CO-OPs” Co-Ops will be non-profit member run plans. 4. What is a Compact Plan? Plans offered across state lines available in 2016. 5. Keeping Your Coverage Initiative - Grandfathered Plans
Obtaining Coverage 48
Employer Coverage Group Employer Coverage Under 50 Employees Are Able To Participate in the Exchange
Small Business Market
50+ Employees
Large Business Market
200+ Employees
Two Sectors
Unable To Participate in the Exchange Until 2016
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Medicare Coverage for individuals that are age 65 or older and qualify with 40 quarters OR under age 65 and qualify due to disability or health status Financing and Increases of Coverage Preventative Care Part D $250 reimbursement for those that reach the donut hole
Eliminate the coverage gap in Part D by 2020 Improve coordination of benefits for dual eligible individuals Obtaining Coverage 50
Medicaid Individuals that qualify financially for State and Federally Funded Coverage Pregnant Women Children Elderly Disabled Those that fall within 138% or below the FPL Federally Funded
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Qualified Health Plans 53
Qualified Health Plans
What Constitutes “Qualified� Essential Health Benefits
Qualified Health Plans 54
Plan Valuation
Definition Qualified Health Plan Is a plan certified through the Department of Health and Human Services as meeting regulations regarding Essential Health Benefits and Actuarial Value
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Definition • 1-100 Small Group Market • Benefits = Typical Employer Plan • Limits >HSA Limits Are Prohibited • Deductibles over 2K (individual) Prohibited • Deductibles over 4K (family) Prohibited • Individual Catastrophic Plans: Under 30 • Essential Health Benefits Covered Qualified Health Plans
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Essential Health Benefits Ambulatory Patient Services
Prescription Drugs
Emergency Services
Rehabilitative & Habilitative Services
Hospitalization
Laboratory Services
Maternity & Newborn Care
Preventive & Wellness Services Including Chronic Disease
Mental Health, Substance Use, & Behavioral Health Disorders
Pediatric Services Including Oral & Vision Care
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Plan Valuation Actuarial value accounts for the percentage of coverage a plan offers vs. the out-ofpocket expense of the insured. Deductibles, Coinsurance, Co-pays and Cost are all factored in to this valuation.
Qualified Health Plans
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Plan Valuation 90%
Platinum
80%
Gold
70%
Silver Bronze
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60%
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Hot Topics
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Hot Topics Small Businesses Rewards & Rebates
Wellness Programs
Birth Control & Abortions
Penalties
Exemptions & Safe Harbor Rules
Hot Topics 62
Small Businesses Credits and Incentives to Provide Benefits
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Employers could vary premiums
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Workplace Wellness Grants Offered - Less than 100 workers - Employees must work at least 25 hrs wk - Must meet “wellness” criteria
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Wellness Programs
Mr. Richard Reinholz Lowe’s YMCA, Mooresville richard.reinholz@ymcacharlotte.org
Hot Topics 64
S at work Exceptional Programs & Services With over 19 locations and a team of professional health and wellness specialists, the Y can provide countless ways to improve the health of your company. Our programs and services support the athlete to those with medical needs. We customize our approach with a special focus on encouraging teamwork and fun.
Professional Staff The YMCA has long term success in helping individuals make positive behavior change. Our success is due to our staff. The Y is the only provider who can offer a team of certified professionals in the following specialties to help employees reach their goals: – Exercise Physiologists – Personal Trainers – Group Exercise & Fitness Instructors – On-site Registered Dietitians in partnership with Carolinas HealthCare System – On-site Registered Nurses in partnership with Carolinas HealthCare System – Lifestyle & Weight Management Instructors – Member Retention Specialists – Yoga & Pilates Instructors – Cycle Instructors – Sport Conditioning coaches 65
Additional Benefits to Employees of being a Y Member: – – – – – – – –
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Free drop-in childcare to ensure your child is in a safe environment while you work out. Bible studies Access to 11 outdoor pools and waterparks as well as the Lake Norman YMCA lakefront. Access to an onsite Registered Nurse or Registered Dietitian through Carolina’s HealthCare System. Hundreds of group exercise classes offered weekly including Zumba®, cycle, yoga, Pilates, BodyPump®, water fitness and more. Volunteer opportunities that allow you to give back to families & communities. Member benefits around town. Nationwide access: more than 2,400 YMCAs across the country will honor your YMCA of Greater Charlotte membership as part of the YMCA's AWAY program (Always Welcome at the Y). Childcare programs that keep kids happy and healthy so parents too can focus on their own health such as: • Swimming programs • Sports • Preschool • Afterschool • Day Camp • Teens
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Additional Benefits to Employees of being a Y Member: – – – – – – – –
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Free drop-in childcare to ensure your child is in a safe environment while you work out. Bible studies Access to 11 outdoor pools and waterparks as well as the Lake Norman YMCA lakefront. Access to an onsite Registered Nurse or Registered Dietitian through Carolina’s HealthCare System. Hundreds of group exercise classes offered weekly including Zumba®, cycle, yoga, Pilates, BodyPump®, water fitness and more. Volunteer opportunities that allow you to give back to families & communities. Member benefits around town. Nationwide access: more than 2,400 YMCAs across the country will honor your YMCA of Greater Charlotte membership as part of the YMCA's AWAY program (Always Welcome at the Y). Childcare programs that keep kids happy and healthy so parents too can focus on their own health such as: • Swimming programs • Sports • Preschool • Afterschool • Day Camp • Teens
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CHS and YMCA of Greater Charlo3e Carolinas HealthCare System, one of the na8on’s leading and most innova8ve healthcare organiza8ons, provides a full spectrum of healthcare and wellness programs throughout North and South Carolina. Carolinas HealthCare System works to improve and enhance the overall health and wellbeing of its communi8es through high quality pa8ent care, educa8on and research programs, and a variety of collabora8ve partnerships and ini8a8ves. The YMCA, through the partnership with Carolinas HealthCare System, is able to provide the following wellness assessments and services to employers:
Personal Health Survey
Online or Paper Ques=onnaire (Vendor: Applied Health Analy=cs)
Biometric Screenings
Body Mass Index, Waist Circumference & Blood Pressure Measurements
Lipid Profile & Glucose Screenings
Finger s=ck (Cholestech LDX) or Venipuncture
One-‐on-‐One Risk Factor Counseling
One-‐=me individual counseling session to review results 68
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Investment Matching Concept The YMCA of Greater Charlo3e will match a companies investment in their employees health and well-‐being. • •
The YMCA will match companies investment in membership up to 40% with centralized billing and up to 30 % without centralized billing. The investment matching will come through the following programs / services – Health Coaching – Personal Health Survey – Biometric Screening – Lipid Profile and Glucose Screening – One on One Risk Factor Counseling – Personal Training – On-‐Site Group Exercise Classes – Wellness Challenges – ETC.
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Wellness Programs Employers Give Discount or Rebate of Premium 1. Currently cannot exceed 30% cost of employee-only coverage but may increase to 50% 2. Example: • Emily’s Health Coverage Per Month = $300 • Emily is taking steps to become more active by utilizing her gym membership
offered through the company wellness program.
• If Emily reports she worked out at least 3 times per week, employer can
rebate or discount her premiums by an additional 30%.
• Employer pays 50% of premium - in Emily’s case, $150. • If Emily works out, employer pays $90+ • Emily’s Monthly Cost = $60
Hot Topics 71
Play or Pay: Penalties Individuals failing to carry coverage
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Reporting Penalty Schedule
Flat Fee Phase In $95 in 2014 $325 in 2015 $695 in 2016 flat fee 1.0% of taxable income in 2014 2.0% of taxable income in 2015 2.5% of taxable income in 2016
Large Employers (50+ employees)
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$2,000-$3,000 per employee (with the first 30 excluded) Cadillac Plan = 40% Excise Tax
Hot Topics 72
Birth Control & Abortions 1. This is a State matter 2. The primary complaint is that tax-payer dollars and penalty charges are going to fund abortions and the “morning after� pill The act has attempted to mitigate this issue by creating two payments for 1 plan premium for subsidized plans - 1st bucket = Taxpayer $$ - 2nd bucket = Insured $$ IF services rendered include birth control measures or abortions, the funding comes from bucket #2. Many lawsuits have been filed against the ACA for this one issue!
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Exemptions & Safe Harbor ➡
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Granted for financial hardship, religious objections, American Indians… for those without coverage for less than three months… including undocumented immigrants, incarcerated individuals, those for whom the lowest cost plan option exceeds 8% of an individual’s income, and those with incomes below the tax filing threshold.
Hot Topics 74
Resources
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Health Care Reform Critical Dates Date
Year
Action Item
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Sep 1
2013
Employer Must notify employees of open enrollment and options regarding exchanges
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Oct
2013
Open Enrollment Begins; Exchanges Available
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Dec
2013
All-inclusive Health Policies Terminate at Midnight
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Jan
2014
Affordable Care Act becomes fully active
2014
Last month to obtain insurance without penalties imposed. Open enrollment = Oct 13–Feb 14
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Feb
6 www.TheIXG.com
2016
Large group market can access insurance plans through exchanges
Resources www.TheIXG.com
Utilize our consultancy services to stay on top of the law and implement standards that allow you to be in compliance with Federal and State level requirements
www.Healthcare.gov
High level view of the policies and timeline
www.dol.gov
US Department of Labor
www.cbo.gov
US Congressional Budget Office
IXG Consulting Group
www.hhs.gov/ocr
Health and Human Services – Office of Civil Rights
Apha.org
The American Public Health Association offers reports covering many areas of our nation’s health
NAIC.org
National Association of Insurance Commissioners – timeline and commentary on the law
http://healthreform.kff.org
Henry J. Kaiser Foundation – Great resource for relatable terms and applicable examples of the law
Resources
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Special Thanks To:
Marty Halloran CPA - Cornelius mhalloran@halloranCPA.com
Richard Reinholz YCommunity Health & Wellness Senior Director Lowe’s YMCA - Mooresville richard.reinholz@ymcacharlotte.org
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TheIXG.com 79
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