PAI Self-Funded Plan Updates

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Health Care Reform - 2012 Update

February 06, 2012

W-2 Reporting: Further Guidance Issued
Background
Starting with tax year 2011, the Patient Protection and Affordable Care Act (PPACA) requires employers to report the cost of coverage under an employer-sponsored group health plan. In the fall of 2010, the IRS issued Notice 2010-69. It made this requirement optional for all employers in 2011, to give employers more time to update their payroll systems. Last year, the IRS issued Notice 2011-28, which provided further relief for smaller employers filing fewer than 250 W-2 forms. It made the reporting requirement optional for them at least for 2012, and continued this optional treatment for smaller employers until further notice.
 
New Guidance
On Jan. 3, 2012, the IRS issued Notice 2012-9. This amended some of the guidance in its previous Notice 2011-28 and added new guidance, including information on how to report, what coverage to include and how to determine the cost of the coverage.
 
You can find the 2011 Form W-2 at IRS.gov. It includes the codes employers may use to report the cost of coverage under an employer-sponsored group health plan. This reporting is for informational purposes only. It is meant to show employees the value of their health care benefits so they can be more informed consumers. The amount reported does not affect tax liability. The value of the employer contribution to health coverage still can be excluded from an employee's income, and it is not taxable. You should also visit the IRS website to view IR-2011-31 and its frequently asked questions.
 
As always, we encourage our employer groups to consult with the tax advisers on this new guidance.
 
Uniform Summaries of Benefits and Coverage
Under the PPACA, insurance plans originally were to issue Uniform Summaries of Benefits and Coverage (SBC) to their members starting March 23, 2012. On Nov. 17, 2011, the Department of Labor issued sub-regulatory guidance in the form of Q&As (http://www.dol.gov/ebsa/faqs/faqaca7.
html). These Q&As indicate that until final rules are issued on SBCs, insurers and employers are not required to comply with the requirement. The guidance indicated that once the final rules are issued, there will be an "applicability date that gives group health plans and health insurance issuers sufficient time to comply."
 
Healthcare Symposiums
BlueCross BlueShield of South Carolina will offer a Healthcare Reform Symposium II for appointed agents in March 2012 on the following dates and locations:
 
3/26 Columbia Metropolitan Convention Center
3/27 Greenville Marriott
3/28 Charleston Marriott
3/29 Myrtle Beach Convention Center
 
The symposium’s format will be similar to the format of those held in September 2010. It will include a legislative update and a presentation on implementation activities - those that have taken place and those yet to come. These will again be followed by a Q&A session with the marketing vice presidents from each major line of business.

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