Small Groups Compliance Checklist

Small Employer 2016 ACA Compliance


The Affordable Care Act (ACA) has made significant changes to group health plans since the law was enacted over four years ago. Many of the key reforms became effective in 2014, including health plan design changes, increased wellness program incentives and reinsurance fees. Additional reforms took effect in 2015, including the shared responsibility penalty and reporting requirements. At Michigan Planners, Inc. we strive to provide you easy-to-understand communication materials regarding this crucial and complicated topic. Outlined here, we have provided you with a simple checklist of what you need to know regarding your benefit programs beginning in 2015 and what you can expect in 2016.

  • Small Group Definition: Employers with 100 full-time employee equivalents or less.
  • Cost Sharing Limits: Annual out-of-pocket maximum limits for 2016 are $6,850 single / $13,700 family. High deductible health plan annual out-of-pocket limits for 2016 are $6,550 single / $13,100 family.
  • Health FSA Contributions: Beginning in 2013, the ACA placed an annual limit on an employee’s pre-tax contributions to a health flexible spending account (FSA). Limits for 2016 have not yet been announced.
  • Health Savings Account Contributions: For the 2016 calendar year, the maximum single contribution into an H.S.A. account is $3,350 and the maximum family contribution is $6,750. Age 55+ catch-up contribution will remain at an additional $1,000.
  • Mandated Pediatric Dental and Vision: As a reminder, pediatric dental and vision benefits must be included in all fully-insured programs.
  • Excessive Waiting Periods: A group health plan or issuer may not impose a waiting period that exceeds 90 days. Typically employers change their waiting periods to 91st day or first billing following 60 days.
  • Member-level rating: Member-level rating will continue to be in effect for 2016. Each member’s rate is based on their age. A composite rating structure can be used to calculate employee contributions.
  • Reporting of Coverage: The ACA requires ALEs to report information to the IRS and to employees regarding the employer-sponsored health coverage. The IRS will use the information reported to verify employer sponsored coverage and administer the employer shared responsibility provisions. All ALEs must report under section 6056 for 2015. The first returns will be due in 2016 for health plan coverage provided in 2015.
    • Small group (fully-insured): Insurance carriers will file the appropriate forms with the IRS that are required in Section 6055.
    • Small group (self-funded): Employers are required to submit the appropriate forms with the IRS that are required in Section 6055.


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