If you own a dental practice, you have a number of responsibilities to your employees, regardless of the size of your organization. One of those responsibilities is to ensure that employer health plans are administered properly – a task which may sound simple, but in practice can be anything but. That is because even the most informed and intelligent employers may be finding themselves confused by all of the requirements under the Affordable Care Act (ACA).
Fortunately, the IRS has recognized the challenge that understanding the ACA can be, and in response it has released new guidelines intended to assist employers with questions they may have on a number of healthcare-related topics. IRS Notice 2015-87 provides guidance on multiple topics relevant for employers, including, but not limited to, the following issues:
1) Opt-out payments. Many employers give their employees options when it comes to their health plans. One of those options is to provide employees who choose not to enroll in the employer-provided plan with an opt-out payment. The IRS Notice clarifies that this payment should be counted as part of an employee’s premium payment when determining whether the employer is satisfying the affordability provisions of the Affordable Care Act.
(2) HRAs and the ACA. What sounds like a confusing acronym battle is actually a pretty common issue: Can funds from Health Reimbursement Arrangements (HRAs) be used to reimburse premiums paid for market coverage? Notice 2015-87 answers multiple questions related to the intersection of HRAs and the ACA.
(3) COBRA and FSA carryovers. The notice addresses issues as to how COBRA intersects with health flexible spending account plans (FSAs) when those FSAs offer carryover options.
Regardless of whether your dental practice is directly affected by any of the issues above, it is important to stay on top of healthcare-related issues in the workplace. This IRS Notice is recommended reading for anyone looking to ensure compliance with IRS regulations today and into the future.
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