Cabrillo Collegecabrillo.edu/services/hr/benefits/Benefits2015-16/051415Cabrillo AC… · The Cadillac Tax will require employers to pay an 40% excise tax on any portion of health

Cabrillo College ACA Overview May 2015

© 2015 Alliant Insurance Services, Inc. All rights reserved. Alliant Employee Benefits, a division of Alliant Insurance Services, Inc. CA License No. 0C36861

PURPOSE OF HEALTH CARE REFORM

2

Improve access to healthcare

Make coverage more affordable

Require health insurance Larger employers must offer

comprehensive, affordable coverage Create healthcare Exchanges No pre-existing conditions Coverage becomes guarantee issue Dependent coverage up to age 26 No cost preventive care

Federal subsidies for lower income families Caps on employee contributions Expanded access to Medicaid Caps on non-claims costs Minimize cost-shifting for uninsured care Pilot programs to address healthcare cost,

quality and transparency


ACA OVERVIEW WHAT HAS THE COLLEGE ALREADY DONE TO COMPLY?

3

Cover dependent children up to age 26

Eliminate annual and lifetime maximums

Offer no cost Preventive Care

Meet new employee communication requirements Summary of Benefit Coverage Marketplace Exchange Notice

Meet governmental reporting requirements – W2 Reporting

Pay certain applicable fees and taxes

Reinsurance Fee – Support state exchange risk pools PCORI – Funds a private, not for profit organization to help providers, payers and policy makers

improve healthcare Industry Tax – Funds general operations of the ACA 2% to 4% of premium

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PURPOSE OF HEALTH CARE REFORM

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2015 2016+ Coverage & Benefit Mandates

• Employer “Pay or Play” begins if 100+ FTEs (at renewal in most cases)

• 70% FTE offer threshold (2015 only)

• Employer “Pay or Play” applies to 50+ FTEs • 95% FTE offer threshold

Taxes & Fees • Health industry tax of about 2% (included in insured rates) – Paid by SISC

• PCORI fees of $2 PEPY due 7/31 for self-funded – Paid by SISC

• Reinsurance fee payment of $63 PEPY – Paid by SISC

• Health industry tax – Paid by SISC • PCORI fees (through 2019) – Paid by SISC • Reinsurance fee payment of $44 PEPY due

1/16– Paid by SISC • Cadillac tax of 40% on high value plans

(2018+)

Tracking & Reporting

• Coverage value on W-2s (if issue 250+ W-2s) • Coverage level reporting to participants

(1/31/16) and government (3/31/16)

• Coverage value on W-2s • Coverage level reporting to participants

(1/31) and government (3/31) for prior year


ACA OVERVIEW FUTURE COMPLIANCE

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IRS Reporting - 2016 The ACA requires employers to provide certain reporting to the IRS and

Employees in 2016 to prove coverage offered is sufficient Alliant will ensure that the College is aware of all of the IRS reporting

Guidelines

Cadillac Tax – 2018 The Cadillac Tax will require employers to pay an 40% excise tax on any

portion of health insurance premium that is over a pre-determined threshold Assuming trend increases for the next three years, health insurance

premiums would elevate above the current identified thresholds


ACA OVERVIEW PAY OR PLAY

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• Employee contribution for single coverage of lowest cost plan does not exceed 9.5% of employee’s income (W-2 income, actual wages, or federal poverty level safe harbor)

Affordable

• Coverage meets minimum value (60% actuarial value) requirement and meets Minimum Essential Coverage requirements

Comprehensive

• Offer coverage to all employees working 30+ hours per week and their eligible dependents (spouses not required)

• Safe-harbors exist to define 30 hour determination

Full-Time Employees

… or the employer may pay annual penalties of $2,080 or $3,120 per employee for 2015

The Affordable Care Act requires large employers (50+ employees) to offer medical coverage that is…


ACA OVERVIEW PAY OR PLAY PENALTIES

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Penalty A Employer does NOT offer

Minimum Essential Coverage (MEC) to “substantially all full-

time ee”

$2,080 per each full time

employee less 30 (less 80 in 2015)

Penalty B Employer does offer MEC,

but it is not Affordable

1 FT EE goes to the Exchange, enrolls and

gets subsidized coverage

$3,120 per each subsidized employee

Effective October 1, 2015 for Cabrillo College (if the District offers affordable coverage to all ACA FT employees as of October 1, otherwise the effective date is January 1, 2015

© 2015 Alliant Insurance Services, Inc. All rights reserved. Alliant Employee Benefits, a division of Alliant Insurance Services, Inc. CA License No. 0C36861 8

To avoid Penalty A, Employers are required: To offer access to coverage to essentially all (95% or more in) of FT employees

(as defined) and dependents up to age 26 but there is no mandate to offer coverage for spouses “Currently defined” - Variable or part time employees, including substitutes,

could be considered full time and These employees could expose the College to Penalty A if they represent

more than 5% of the full time work force 70% for 2015 – New – Moves to 95% or more starting in 2016 No requirement to pay for dependent coverage

ACA OVERVIEW TO AVOID PENALTY A


To avoid Penalty B At least one plan offered to full time employees and dependent children up to

age 26 must be: Of minimum value (60% of medical expenses paid by plan) Affordable for self-only coverage – 9.5% or less of Box1 Wages, FPL, or

Rate of Pay, depending on applicable Safe Harbor No requirement by ACA to offer coverage to spouses No requirement to contribute to cost of dependents

Penalty B is $3,120 per year ($260 per month) on any employee that meets all

of these requirements Qualifies for a federal subsidy from the Exchange based on total

household income (excluding MediCal eligible participants) Elects and receives subsidized coverage from the Exchange Demonstrates that the lowest cost, minimum value coverage offered by

the employer was not affordable for self-only coverage

ACA OVERVIEW TO AVOID PENALTY B


ACA OVERVIEW SAFE HARBOR AFFORDABILITY TESTS

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The IRS has developed safe harbor tests A safe harbor is a means of complying with the law using a prescribed test

W2 Earnings Safe Harbor Test

The employee share of the premium required for the least costly, self only coverage must be less than 9.5% of the W2, box 1 wages paid to the employee

Rate of Pay Safe Harbor Test

Single coverage employee cost is less than 9.5% of employee’s lowest hourly wage x 130

Federal Poverty Level Safe Harbor Test

This method examines whether the cost of coverage exceeds 9.5% of the Federal Poverty Line (FPL)

An employer satisfies the FPL safe harbor if the employee’s contribution for the lowest cost plan for self-only coverage does not exceed 9.5% of FPL (See chart)


ACA OVERVIEW WHO IS ELIGIBLE FOR A SUBSIDY?

2014 Federal Poverty Level (not related to the FPL Affordability Safe Harbor for Employers)

Household size

Household income

Maximum contribution*

Household income

Maximum contribution*

1 $16,105 $127.50 $46,680 $369.552 $21,707 $171.84 $62,920 $498.114 $27,310 $216.20 $95,400 $755.256 $32,913 $260.56 $127,880 $1,012.38

138% federal poverty level 400% federal poverty level

*Maximum contribution is based on monthly maximum affordable employee contribution for single coverage based on 9.56% of household income.

The FPL safe harbor is based only on the FPL for a single individual for the applicable calendar year (divided by 12 – to get the monthly amount). Employers may use the FPL guidelines in effect six months prior to the beginning of the plan year.


Requirements to avoid penalties: Coverage available must be at least a minimum actuarial value (60% of the cost of services) and must be affordable for the employee coverage on the lowest cost plan offered by the College. Solution: SISC renewals include a minimum value “Bronze” plan. It will not count against the maximum permitted number of plans SISC allows a group to offer. It will include only the minimum coverage required by ACA It will only feature two-tiers: Employee Only and Employee + Child(ren). It will NOT include an option for spousal/domestic partner coverage. It will NOT be offered with any option for dental, vision or life coverage.

The primary purpose of the plan will be to allow Colleges to avoid exposure to Penalty A and B by: offering access to a minimum value plan to employees who HAD NOT previously

qualified for SISC coverage and, providing a more affordable plan for single only coverage to employees who HAD

previously qualified for SISC coverage.

ACA OVERVIEW TO AVOID PENALTIES - SISC PLAN SOLUTION


“AT RISK” COLLEGE PENALTY B SCENARIOS

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Employee enrolls in College coverage No Penalty

Employee enrolls in spouse’s health plan No Penalty

Employee is eligible to enroll in spouse’s “affordable” health plan No Penalty

Employee remains uninsured No Penalty

Employee’s household income qualifies for MediCal No Penalty

Employee enrolls in individual coverage outside the Exchange No Penalty

Employee enrolls in Exchange and household income is greater than 400% of the federal poverty level No Penalty

Employee enrolls in the Exchange and, • Demonstrates they were full time employee and, College pays $260 • Demonstrates College coverage was unaffordable and, per month penalty • Employee receives a federal subsidy


Full-Time Employee

Based on facts and circumstances at their start date, the employee is expected to work an average of 30+ hours of service a week (regardless of how long their assignment is expected to be, unless Seasonal) – Offer Benefits

Part Time Employee

Reasonably expected at start date to work an average of less than 30 hours of service per week – Initial Measurement Period

New Variable Hour Employee

Based on the facts and circumstances at their start date, the employer cannot determine whether they will work 30+ or more hours of service a week because their hours are variable or otherwise uncertain – Initial Measurement Period

New Seasonal Employee

Hired into a position for which customary annual employment is six months or less – Initial Measurement Period

ACA OVERVIEW EMPLOYEE CLASSES

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Adjunct Professors

• “IRS suggests: for each classroom hour, count 2.25 hours (to account for preparation and grading) + an hour per week for each additional hour outside of the classroom performing required duties”

• Must be reasonable method

Volunteers

• Allows exclusion of bona fide volunteers” (Note: many employees who receive stipends still must be included as employees under the employer mandate)

Students in Work Study Programs

• Excludes hours of service for positions subsidized through the federal work-study program or similar state program

ACA OVERVIEW SPECIAL CONCERNS: NEW GUIDANCE

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ACA OVERVIEW CALCULATING HOURS OF SERVICE

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# Regular

hours worked

# Months in

measurement period

# Hours of

paid time off + special

unpaid leave

Average #

hours worked per

month

All employees # Hours of paid time off: include

vacation, PTO, sick time, teacher breaks of at least 4 consecutive weeks

# Hours of special unpaid leave: includes jury duty, USERRA and FMLA. These leaves don’t count against employees.

Rehires Use all hours worked during measurement period if:

Break in service is 13 weeks or less

o 26 weeks or less for education employees

Rule of parity

Can treat as new employee if break in service is more than 13 weeks (26 weeks for education employee)


ACA OVERVIEW BREAK IN SERVICE RULES

Break in Service Rules

Employees must have a break in service of 26 weeks before they can be placed in a new initial measurement period or otherwise treated as a new employee for the purposes of pay or play

For employment breaks of 4 or more weeks, the employer must “credit” hours of service as follows:

Determining the average hours of service per week for the employee during the measurement period, excluding the employment break period, and using that average for the employee for the entire measurement period; or

Crediting the employee with hours of service for the employment break period at a rate equal to the average weekly rate at which the employee was credited during the other weeks in the measurement period.

NOTE Educational organizations are not required to credit employees with more than 501 hours of service for any employment break

period in a calendar year (applies to continuing employees, not rehires; does not include special unpaid leave)

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ACA OVERVIEW ADJUNCT FACULTY

Counting Hours of Service for Adjunct Faculty The Employer Shared Responsibility IRS Section 4980H document,

provides the following guidance for counting hours of service for adjunct faculty members who work variable hours: Employers should use a reasonable method of crediting hours of service that is

consistent with the purposes of section 4980H An instructor’s hours should include not only classroom or other instruction time, but

also include necessary hours that are needed to perform the employee’s duties such as classroom preparation time, etc.

A method of crediting hours of service would not be reasonable if it only accounts for some of an employee’s hours of service with the goal to redefine as non-full time (for employees in positions that traditionally involve more than 30 hours per week). The Final guidance expressly allow crediting an adjunct faculty member with 2 ¼

hours of service per week for each hour of teaching or classroom time as a reasonable method for this test

Other methods can be used as long as they are “reasonable”

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ACA OVERVIEW STUDENT WORKERS AND VOLUNTEERS

Student Workers The final regulations provide that hours of service do not include hours of service performed

by students in positions subsidized through the federal work-study program or a similar state or local program

There is no exception for student workers overall

Volunteers The final regulations do not directly refer to stipend employees, however there is language

included regarding “Bona Fide Volunteers”

Hours of service for purposes of the pay or play rules do not include hours worked as a “bona fide volunteer.” The term “bona fide volunteer” means any employee of a government or tax-exempt entity whose only compensation from that entity or organization is in the form of:

(i) reimbursement for (or reasonable allowance for) reasonable expenses incurred in the performance of services by volunteers; or

(ii) reasonable benefits (including length of service awards) and nominal fees customarily paid by similar entities in connection with the performance of services by volunteers.

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FULL-TIME EMPLOYEES STANDARD MEASUREMENT PERIOD

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Standard Measurement Period

Administrative Period Stability Period

All employed when measurement period begins

Time over which employee hours of service are counted

3-12 months

Time to determine full-time or part-time status based on average hours of service

Up to 90 days

Time during which employee’s full-time or part-time status is locked

Must be at least six (6) months long and cannot be shorter than measurement period

Must = stability period for initial measurement period


May

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1st Standard Measurement Period, start measuring August 1, 2014. Administrative Period 2 months (August 1, 2015 – September 30, 2015). Stability Period 12 months (October 1, 2015 – September 30, 2016).

Jun-

14

Jul-1

4

Aug-

14

Sep-

14

Oct

-14

Nov

-14

Dec-

14

Jan-

15

Feb-

15

Mar

-15

Apr-

15

May

-15

Jun-

15

Jul-1

5

Aug-

15

1st Stability Period

Sep-

15

Oct

-15

Nov

-15

Dec-

15

Jan-

16

Feb-

16

Mar

-16

Apr-

16

May

-16

Jun-

16

2014 2015 2016

1st Standard Measurement Period

2nd Standard Measurement Period

PAY OR PLAY – FULL-TIME EE DETERMINATION

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Standard Measurement Period – October 1 plan year

Admin


FULL TIME EMPLOYEES INITIAL MEASUREMENT PERIOD

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Initial Measurement Period

Administrative Period Stability Period

Time over which new employee hours of service are counted

3-12 months Start on DOH or 1st of

month following

Time to determine full-time or part-time status based on average hours of service

Up to 90 days Can split admin

period if IMP starts 1st of the month following DOH

New variable hour and/or seasonal employees

Max duration 13 months + fraction

Time during which employee’s full-time or part-time status is locked

Can’t be more than one month longer than Initial measurement period

Must = stability period for ongoing measurement period

Limited for employees deemed part-time


ACA OVERVIEW MEASUREMENT PERIODS

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Some basic rules for easier administration:

Use 12 month initial measurement periods (IMPs) and associated 12 month stability periods – effectively have 12 IMPs in a year

Start tracking new variable hour/seasonal employees on first of the month following date of hire

o Note—new employees hired to work full-time must be offered coverage no later than 60 days of date of hire (CA) – recently repealed back to 90 days

New variable hour, seasonal or part time employees whose hours of service measure as full-time will be considered full-time during the associated stability period

An ongoing measured employee will always be in a measurement period and a stability period


PROPOSED REPORTING REQUIREMENTS FORM 1094-C AND 1095-C

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Starts in 2016 for 2015 calendar year

Employer must report to the IRS by March 31, 2016 and each March thereafter, an electronic listing of every employee and retiree including all dependents enrolled in medical coverage and the months of coverage (College must e-file) Name Social Residence Months Covered

Employer must issue to each employee by January 31, 2016 and each January

thereafter, a certificate of coverage including the above information for the employee or retiree to file with their tax return to avoid the individual mandate penalty

SISC Solution: To the extent SISC can do this as a service to member Colleges, or, if not as a service, then provide the information needed to do this to the member Colleges, SISC will.


ACA OVERVIEW: CADILLAC TAX WHAT IS A CADILLAC HEALTH PLAN ?

25

The Affordable Care Act includes a tax on benefit rich plans, known as the “Cadillac Tax”

The tax is for health plans that have lower out-of-pocket costs and most health care services are covered

The excise tax is 40% on any health plan premium over the following thresholds:

$10,200 for Single Coverage

$27,500 for Family Coverage

Higher limit for workforces with older populations

These amounts are benchmarked to the Federal Employee Health Benefit Plan (FEHBP)

The Cadillac Tax includes the following:

Medical premiums

Non-Excepted Dental and Vision Premiums

FSA, HRA and HSA Contributions

The Cadillac Tax is meant to be charged to plan insurers and plan sponsors and would be collected and used to help defray America's multi-trillion dollar health care plan

The Cadillac Tax is scheduled to become effective January 1, 2018


Cadillac Tax - Illustration

26

Cabrillo College

$10,200.00 Current Cadillac Threshold (2018) - Single $11,850.00 Current Cadillac Threshold (2018) - Single

$27,500.00 Current Cadillac Threshold (2018) - Family $30,950.00 Current Cadillac Threshold (2018) - FamilyBlue Shield HMO $30-20% - Actives

Current Enrollment

Current Monthly Cost

Current Annual Cost

Projected Annual Cost 2018 2018 Cadillac TaxProjected Tax - 40%

Annual Increase N/A N/A N/A 6% 9% 12% 6% 9% 12%Employee 33 $742.00 $8,904 $10,605 $11,531 $12,509 $162 $532 $924Employee + 1 7 $1,453.00 $17,436 $20,767 $22,580 $24,496 $0 $0 $0

Employee & Family 27 $2,043.00 $24,516 $29,199 $31,749 $34,443 $680 $1,700 $2,777

Projected Tax $23,692 $63,457 $105,472

Blue Shield HMO $30-20% - Early RetireesCurrent

EnrollmentCurrent

Monthly CostCurrent

Annual CostProjected Annual Cost 2018 2018 Cadillac Tax

Projected Tax - 40%Annual Increase N/A N/A N/A 6% 9% 12% 6% 9% 12%Employee 0 $742.00 $8,904 $10,605 $11,531 $12,509 $0 $0 $264Employee + 1 1 $1,453.00 $17,436 $20,767 $22,580 $24,496 $0 $0 $0Employee & Family 0 $2,043.00 $24,516 $29,199 $31,749 $34,443 $0 $320 $1,397

Projected Tax $0 $0 $0

Blue Shield HMO $25-500 w/Chiro - ActivesCurrent

EnrollmentCurrent

Monthly CostCurrent

Annual Cost Projected Annual Cost 20182018 Cadillac Tax

Projected Tax - 40%

Annual Increase N/A N/A N/A 6% 9% 12% 6% 9% 12%Employee 98 $792.00 $9,504 $11,319 $12,308 $13,352 $448 $843 $1,261Employee + 1 48 $1,554.00 $18,648 $22,210 $24,150 $26,199 $0 $0 $0

Employee & Family 90 $2,186.00 $26,232 $31,243 $33,971 $36,854 $1,497 $2,588 $3,742

Projected Tax $178,620 $315,595 $460,322

Blue Shield HMO $25-500 w/Chiro - Early RetireesCurrent

EnrollmentCurrent

Monthly CostCurrent


Projected Tax - 40%Annual Increase N/A N/A N/A 6% 9% 12% 6% 9% 12%Employee 9 $792.00 $9,504 $11,319 $12,308 $13,352 $0 $183 $601Employee + 1 7 $1,554.00 $18,648 $22,210 $24,150 $26,199 $0 $0 $0

Employee & Family 0 $2,186.00 $26,232 $31,243 $33,971 $36,854 $117 $1,208 $2,362

Projected Tax $0 $1,649 $5,409

Actives Early Retirees



27

Cabrillo College


$27,500.00 Current Cadillac Threshold (2018) - Family $30,950.00 Current Cadillac Threshold (2018) - FamilyBlue Shield HMO $10-0 w/Chiro - Actives

Current Enrollment


Current Annual Cost


Annual Increase N/A N/A N/A 6% 9% 12% 6% 9% 12%Employee 14 $980.00 $11,760 $14,006 $15,230 $16,522 $1,523 $2,012 $2,529Employee + 1 15 $1,900.00 $22,800 $27,155 $29,527 $32,032 $0 $811 $1,813Employee & Family 15 $2,653.00 $31,836 $37,917 $41,229 $44,727 $4,167 $5,491 $6,891

Projected Tax $83,819 $122,697 $165,961

Blue Shield HMO $10-0 w/Chiro - Early RetireesCurrent

EnrollmentCurrent

Monthly CostCurrent


Projected Tax - 40%Annual Increase N/A N/A N/A 6% 9% 12% 6% 9% 12%Employee 10 $980.00 $11,760 $14,006 $15,230 $16,522 $863 $1,352 $1,869Employee + 1 6 $1,900.00 $22,800 $27,155 $29,527 $32,032 $0 $0 $433Employee & Family 1 $2,653.00 $31,836 $37,917 $41,229 $44,727 $2,787 $4,111 $5,511

Projected Tax $11,412 $17,630 $26,796

Blue Shield PPO 80-E - ActivesCurrent

EnrollmentCurrent

Monthly CostCurrent


Projected Tax - 40%Annual Increase N/A N/A N/A 6% 9% 12% 6% 9% 12%Employee 29 $968.00 $11,616 $13,835 $15,043 $16,320 $1,454 $1,937 $2,448Employee + 1 17 $1,807.00 $21,684 $25,826 $28,081 $30,464 $0 $233 $1,186Employee & Family 9 $2,679.00 $32,148 $38,289 $41,633 $45,166 $4,316 $5,653 $7,066

Projected Tax $81,004 $111,010 $154,742

Blue Shield PPO 80-E - Early RetireesCurrent

EnrollmentCurrent

Monthly CostCurrent


Projected Tax - 40%Annual Increase N/A N/A N/A 6% 9% 12% 6% 9% 12%Employee 19 $968.00 $11,616 $13,835 $15,043 $16,320 $794 $1,277 $1,788Employee + 1 17 $1,807.00 $21,684 $25,826 $28,081 $30,464 $0 $0 $0

Employee & Family 0 $2,679.00 $32,148 $38,289 $41,633 $45,166 $2,936 $4,273 $5,686

Projected Tax $15,085 $24,267 $33,969




28

Cabrillo College


$27,500.00 Current Cadillac Threshold (2018) - Family $30,950.00 Current Cadillac Threshold (2018) - FamilyBlue Shield PPO 80-J - Actives

Current Enrollment


Current Annual Cost


Annual Increase N/A N/A N/A 6% 9% 12% 6% 9% 12%Employee 15 $861.00 $10,332 $12,306 $13,380 $14,516 $842 $1,272 $1,726Employee + 1 13 $1,607.00 $19,284 $22,968 $24,973 $27,093 $0 $0 $0

Employee & Family 11 $2,382.00 $28,584 $34,044 $37,017 $40,158 $2,618 $3,807 $5,063

Projected Tax $41,427 $60,957 $81,592

Blue Shield PPO 80-J - Early RetireesCurrent

EnrollmentCurrent

Monthly CostCurrent


Projected Tax - 40%Annual Increase N/A N/A N/A 6% 9% 12% 6% 9% 12%Employee 1 $861.00 $10,332 $12,306 $13,380 $14,516 $182 $612 $1,066Employee + 1 1 $1,607.00 $19,284 $22,968 $24,973 $27,093 $0 $0 $0

Employee & Family 0 $2,382.00 $28,584 $34,044 $37,017 $40,158 $1,238 $2,427 $3,683

Projected Tax $182 $612 $1,066

Total Projected Tax

Blue Shield PPO HDHP - B w/HSA Compatibility - ActivesCurrent

EnrollmentCurrent

Monthly CostCurrent


Projected Tax - 40%Annual Increase N/A N/A N/A 6% 9% 12% 6% 9% 12%Employee 27 $701.00 $8,412 $10,019 $10,894 $11,818 $0 $278 $647Employee + 1 3 $1,323.00 $15,876 $18,909 $20,560 $22,305 $0 $0 $0

Employee & Family 3 $1,998.00 $23,976 $28,556 $31,050 $33,685 $422 $1,420 $2,474

Projected Tax $1,267 $11,752 $24,899

Total Projected Tax

Blue Shield PPO HDHP - B w/HSA Compatibility - Early RetireesCurrent

EnrollmentCurrent

Monthly CostCurrent


Projected Tax - 40%Annual Increase N/A N/A N/A 6% 9% 12% 6% 9% 12%Employee 1 $701.00 $8,412 $10,019 $10,894 $11,818 $0 $0 $0

Employee + 1 0 $1,323.00 $15,876 $18,909 $20,560 $22,305 $0 $0 $0

Employee & Family 0 $1,998.00 $23,976 $28,556 $31,050 $33,685 $0 $40 $1,094

Projected Tax $0 $0 $0

Total Projected Tax $436,507 $729,626 $1,060,228



DISCLAIMER

29

The Affordable Care Act (“ACA”) is an extraordinarily complex law that will impact all areas of medical insurance in the U.S. Both federal and state agencies have been and will continue to issue temporary and final regulations that materially impact compliance requirements and necessitate new or modified compliance actions. This document and the related resources are intended to support a best practice approach to ACA compliance based on known regulations and practical responses to an evolving landscape. ACA compliance will be an ongoing process that will require regular updates to an employer’s strategy based on new regulations and marketplace developments. This document provides general information regarding the mandates under the Affordable Care Act (ACA). It does not provide a review of, or ensure compliance with, ACA mandates. Alliant Insurance Services, Inc. does not provide legal advice or legal opinions. Please consult counsel if a formal legal opinion is desired.

Public Entity Benefits Group 100 Pine Street, 11th Floor San Francisco, CA 94111

Documents

Cabrillo Collegecabrillo.edu/services/hr/benefits/Benefits2015-16/051415Cabrillo AC… · The Cadillac Tax will require employers to pay an 40% excise tax on any portion of health