While the Employer mandate has indeed been delayed – Obamacare Midsize Employer Mandate Delayed Till 2016 the following 2014 rules must be followed. The PPACA excise tax of $100/day may be levied.
- No waiting periods in excess of 90 days
- No preexisting condition exclusions
- No discrimination against individual participants and beneficiaries based on health status
- No discrimination in health care providers
- No lifetime or annual limits on essential health benefits – Essential Health Benefits Not Delayed
- No rescissions of coverage
- Cost-sharing limitations on essential health benefits
- Coverage for individuals participating in approved clinical trials
- Coverage of preventive health services – Preventive care coverage
- Extension of dependent coverage until age 26 –Dependent coverage extended
- Periodic disclosures required in summary of benefits and coverage – New Summary of Benefits Coverage Notice
- Health plan reporting requirements
- No discrimination in favor of highly compensated individuals – awaiting further guidance and definitions
- Health plan claim and appeals protections
- Patient protections, including the selection of primary care provider, coverage of emergency services, and access to pediatric, obstetrical and gynecological care providers
Importantly, the excise tax will not be assessed if an employer can demonstrate that it did not know, and exercising reasonable diligence would not have known, of a violation. Further, the excise tax will not be assessed if the failure is due to reasonable cause and not willful neglect and it is corrected within the 30-day period beginning on the first date an employer knows, or exercising reasonable diligence would have known, that the failure existed. This limited correction window makes identifying and promptly correcting any potential errors of utmost importance.
For more information on compliance please contact our team at Millennium Medical Solutions Corp (855)667-4621.