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End of Year PPACA Employer Checklist

Pay PCORI Fee by July 31, 2013 (deadline for calendar year plans, see discussion below). Distribute exchange notices to all employees by October 1, 2013. A model notice is available on the U.S. Department of Labor’s (“DOL“) website, but requires employer customization. Distribute to new hires within 14 days after hire. Distribute Summaries of Benefits and Coverage (“SBCs“) during open enrollment. New model SBC templates are available on the DOL website. Amend plan documents and Summary Plan Descriptions (“SPDs“) to reflect changes effective for the 2014 plan year, including: No pre-existing condition exclusions (all plans); Waiting period no longer than 90 days (all plans); Remove any restricted annual limits on essential health benefits (all plans); Remove exclusion of children eligible for other employer-sponsored coverage (grandfathered plans); Limits on out-of-pocket maximum (apply copays to max) (non-grandfathered plans); Clinical trial coverage (non-grandfathered plans); Nondiscrimination against providers (non-grandfathered plans); and Limits on deductible… Continue Reading

July 31 Deadline Approaching for Submitting PCORI Fees

The deadline for most applicable self-insured health plans (including calendar year plans) to report and remit the Patient-Centered Outcomes Research Institute (“PCORI“) fee due under the Patient Protection and Affordable Care Act (“PPACA“) is July?á31,?á2013.?á The PCORI fee is due no later than July 31 of the calendar year immediately following the last day of the plan year to which the fee applies.?á Plans should use the revised version of Form 720 recently released by the Internal Revenue Service to report and remit the PCORI fee. The revised Form 720 can be found?áhere. Instructions for the revised Form 720 can be found here.

July 2013