Proposed Revisions to SBC and Uniform Glossary Modifications

On February 22, 2016, the Departments of Labor, Treasury, and Health and Human Services (“the Departments”) released proposed updates to the Uniform Summary of Benefits and Coverage (SBC) template, instructions, and Uniform Glossary (“glossary”). The proposed documents build largely on the revised versions first proposed in December 2014; however, they incorporate additional stakeholder feedback—primarily from the NAIC—and the Departments are requesting public comments through the end of March before the documents are finalized.

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ACA Developments – House Fails to Override ACA Veto

On Tuesday, February 2 by a vote of 241 to 186 the House of Representatives failed to override President Obama’s veto of a budget reconciliation legislation that would have dismantled major portions of the Affordable Care Act (ACA). Specifically, the legislation had proposed to repeal much of the ACA, including the excise tax on high value employer-sponsored health care benefits.

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Form 1095 – Employee Communications

Many employers want to provide some type of communication along with, or before, the distribution of Form 1095s to relevant employees. Although any employee communication must be tailored to meet the employer’s specific circumstances, some general concepts are addressed here that can be adjusted as appropriate to help employees understand why Form 1095s are being provided, what type of information they provide, and how they are to be used.

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Cadillac Tax – Delayed Effective Date

In December, the Consolidated Appropriations Act, 2016 was signed into law which, amongst other provisions, effectively delayed the excise tax on high-cost health coverage (also known as the “Cadillac tax”) until January 1, 2020. In addition, the law made the excise tax deductible and provides for a study to determine whether appropriate age and gender benchmarks are being used to determine the Cadillac tax threshold adjustments.

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