2015 will be the first real test from an employer perspective on the mandates under the Patient Protection and Affordable Care Act (“PPACA”). Most employers that have to comply with the PPACA mandates found that their plans typically met the minimum requirements. Over the last few years as some of the new insurance mandates were added, they found that it was relatively straightforward (albeit at a cost and some administrative complexity) to get their medical plans into compliance. Therefore, for 2015 most will find that their plans meet the minimum mandates as well. That said, there are several issues that employers will struggle with in 2015 and heading into 2016.
PPACA requires much more reporting than employers had to deal with in the past. The annual 5500 was a relatively straightforward form but for 2015 employers will have to begin gathering and reporting (with the first report due in 2016) much more detailed information on plan participants and the coverage that they receive. The reporting will go both to the IRS and the individuals covered by the plan.
This year will see if the planning for the full implementation has been effective. Employers in industries where large numbers of employees have not previously had coverage for a variety of reasons have been struggling. They need to know how many hours people work and how often in order to determine whether those individuals are part-time or full-time employees for purposes of the PPACA coverage mandates. Full-time has been defined as 30 hours per week on average, which is significantly fewer hours than had traditionally been the case for most employers.
As we move into 2015 it will be interesting to see how these uncertainties play out. With the new political realities in Congress it will also be an interesting year to see if the President is truly open to making some changes to PPACA (as he has indicated) or whether there will be continued roadblocks in ironing out the issues in the act.