Spotlight News at michbusiness.org

The Patient Protection and Affordable Care Act (“PPACA”) mandates that employers and their group health plans issue SBCs on an annual basis before reenrollment in a group health plan and upon initial eligibility.  The purpose of the SBC is to provide individuals with summary information about the employer sponsored group health plan in a format that is intended to be easy for individuals to understand while allowing individuals to compare health plan options and better understand their scope of coverage. 

In Michigan, 299,750 people signed up for coverage through the Health Insurance Marketplace

The Affordable Care Act requires employers to report the cost of coverage under an employer-sponsored group health plan. To allow employers more time to update their payroll systems, Notice 2010-69, issued in fall 2010, made this requirement optional for all employers in 2011. IRS Notice 2011-28 provided further relief by making this requirement optional for certain smaller employers for 2012 Forms W-2 (meaning the Forms W-2 for calendar year 2012 generally furnished to employees in 2013). Notice 2012-9, issued in January 2012, restates and clarifies guidance in Notice 2011-28. It provides guidance for employers that are subject to this requirement for the 2012 Forms W-2 and those that choose to voluntarily comply with it for either 2011 or 2012.

Yesterday, HHS released guidelines for the 2015 federal poverty line (FPL) at $11,770 - up $100 from 2014 - for an individual living in the mainland US.

Large employers can choose whether to send their workers Form 1095-C coverage information notices for the 2014 plan year.

Today, the Internal Revenue Service announced  in Revenue Procedure 2014-61  the annual inflation adjustments for more than 40 tax provisions for 2015, including the tax rate schedules, and other tax changes. This Revenue Procedure provides details about these annual adjustments

The maximum annual employee contribution to a health flexible spending account plan is increasing to $2,550 for 2015 (up $50 from the $2,500 limit that has applied since 2013).

Statement of Enforcement Discretion regarding 45 CFR 162 Subpart E - Standard Unique Health Identifier for Health Plans

The IRS issued a notice on November 4, 2014 concluding that a health plan that does not provide substantial coverage for inpatient hospitalization and/or physician services will not qualify as a "minimum value" plan under the Affordable Care Act.

Question:  One of my clients has 75 employees and has never offered health coverage to its employees and it does not plan do so in the future.  When would it have to comply with the employer mandate, 2015 or 2016?