Over the past few years, you have deployed extra resources and money to navigate and comply with the complexities of the ACA; however, if you have an employee that claims they were not offered affordable, minimum value coverage, they could get coverage on the exchange and with a subsidy.
For applicable large employers, this is another headache prompted by playing by the rules. Say it ain't so!
Here is what you need to know.
If an employee received an advance premium tax credit (APTC) in 2015, you will not be notified. Per an FAQ released by the Center for Consumer Information and Insurance, the notification program will not be implemented until 2016, yet the IRS can determine the employer is still responsible for the annual $3,000 employer shared responsibility payment for this period. Do not fret as the IRS shares the employer will have the right to respond.
If an employee receives an APTC in 2016, you should be notified although there is no guarantee. The notification program will be rolled out in phases. Triggering the notification is contingent upon the employee receiving an APTC and providing the Federally Facilitated Marketplace (FFM) with your current address.
When you are notified, it will be via the mail. From this time, you will have ninety days to appeal to the FFM. The form to do so will be available on www.healthcare.gov. If successful, the employee will be "encouraged" to correct their information or potentially face a tax liability.
Perhaps we are now coming to realize the complexities with the ACA are greater than originally thought and both sides of the aisle are growing closer to simplifying it.
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This is designed only to give general information on the developments actually covered. It is not intended to be a comprehensive summary of recent developments in the law, treat exhaustively the subjects covered, provide legal advice, or render a legal opinion.
Benefit Advisors Network and its smart partners are not attorneys and are not responsible for any legal advice. To fully understand how this or any legal or compliance information affects your unique situation, you should check with a qualified attorney.