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Action Steps for Employers After the Supreme Court's Decision
Morgan Lewis Link to more items from this source
June 28, 2012

"In the coming weeks and months, employers should do the following: [1] Determine whether they are appropriately aggregating group health plan valuation data in order to support 2012 Form W-2 reporting. [2] Prepare to receive, and properly distribute or apply, any Medical Loss Ratio rebates associated with 2011 insured health coverage. [3] Finalize Summary of Benefits and Coverage material for inclusion in the 2013 Open Enrollment package. [4] Complete updates to Summary Plan Descriptions and plan documents to capture and describe the 2011 and 2012 ACA changes to their plan design. [5] Reflect the 2013 plan year $2,500 cap on salary deferral contributions into healthcare spending accounts in 2013 Open Enrollment material, payroll processes, and administration systems. [6] Understand and begin to determine the patient-centered outcomes trust fund fees due in July 2013. [7] Begin to identify whether their group health plans are both affordable and available to full-time employees in order to avoid any shared responsibility penalty in 2014. [8] Prepare for audits associated with their participation in the Early Retiree Reinsurance Program, if applicable. [9] Review possible design changes to retiree drug programs to reflect the change in Medicare Part D subsidy taxation rules. [10] Review future plan design changes to blunt the balance sheet impact of the 2018 Cadillac Tax."

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