CareFirst Rebates – Do you know what to do with it?

CareFirst has started sending out the rebate checks that are required under the provisions of the Affordable Care Act.  If they don’t spend a certain amount of every claims dollar (either  $0.80 or $0.85) on actual claims, they must rebate premiums.  The rebates are calculated by jurisdiction, group size and product.    If you receive a rebate, do you know the rules surrounding distribution?  Here is some guidance:

Download (PDF, 420KB)

Posted on by Melanie Epstein in CareFirst, Health Care Reform Leave a comment

IRS Extends Deadline for Section 6055 and 6056 Reporting

On December 28, 2015, the IRS granted an extension to employers and insurers for the Affordable Care Act reporting required under Sections 6055 and Sections 6056.  Section 6055 reporting is for insurers and self- insured groups that do not meet the 50 lives Applicable Large Employer(ALE) definition.  Section 6056 is for employers meeting the ALE definition.  The extensions are as follows:

1095-C – form distributed to employee extended 2 months from January 31, 2016 to March 31, 2016

1094-C – paper form filed with the IRS extended 3 months from February 29, 2016 to May 31, 2016

1094-C  – electronic filing with the IRS extended 3 months from March 31, 2016 to June 30, 2016

Click here for the full 2014-6 release by the IRS.

Posted on by Melanie Epstein in Health Care Reform Leave a comment

Does your business qualify for the Small Business Health Care Tax Credit?

One of the provisions of the Affordable Care Act (ACA) is the Small Business Health Care Tax Credit.    This tax credit has been available to small businesses since 2010 when the ACA was originally passed.  The current eligibility parameters are:

  1. Businesses including tax-exempt organizations that employ no more than 25 full-time equivalent employees.   Business owners and shareholders and their family members are not considered employees.
  2. Average annual wages (excluding business owners and shareholders and their family members) do not exceed $50,800(as adjusted for inflation).
  3. Business pays at least 50% of the employee’s individual health insurance premium
  4. As of June 1, 2014, the group health plan must be purchased through the SHOP which is the small business health insurance marketplace.  Corporate Coverage is an authorized broker and can help you secure coverage through the SHOP marketplace.
  5. 75% of eligible employees must participate in the plan.  Eligible employees are those that work more than 30 hours per week.   Employees who have other employer sponsored or government sponsored coverage can be excluded from the participation count.  Participation requirements are waived during annual SHOP open enrollment periods.  The first open enrollment period is for applications received between May 15, 2014 and June 15, 2104.
  6. The maximum tax credit is  50%(35% for tax-exempt employers)of the premiums that are paid by the employer not to exceed the average premiums for the small group market in the employers rating area as reported by the Department of Health and Human Services.  The credit is reduced as the employer size increases and the average wages increase.  The largest tax credit would be for an employer with less than 10 employees with average wages of $25,000 or less.
  7. Beginning in 2014, the tax credit is available for two consecutive years.  It is filed on tax form 8941.

Click here for a link to the IRS website that provides the details on this available credit and consult with your accountant.   To assist you in determining your eligibility, two calculators are available:

  1. Click here for the calculator that helps you determine the number of full/time employees/equivalents.
  2. Click here for the calculator that will estimate your tax credit.


If you will be taking advantage of the tax credit, please advise us during our renewal meeting so that we can provide you with the applicable SHOP plans.

Posted on by Melanie Epstein in Health Care Reform Leave a comment


Congratulations to our team for making it through the first open annual individual open enrollment for the new Affordable Care Act plans!  The enrollment period ended March 31, 2014.   The next open enrollment will begin November 15, 2014 and will run through February 15, 2015.

We are now in the Special Open Enrollment Period which started April 1, 2014.    A Special Open Enrollment period is an opportunity to purchase an individual policy outside of the annual open enrollment period as a result of specific events called qualifying events.   These policies can be purchased through the Exchange if you qualify for financial subsidies or directly to the insurance companies if a subsidy is not needed.  You have 60 days in most cases from your Qualifying Event (QE) to purchase the policy.  Here is a list of qualifying events:

*Marriage/Domestic Partnership


*Adoption or Guardianship of a child

*Loss of your health coverage due to:

  1.  Involuntary loss of employer sponsored coverage that meets minimum essential coverage – *(at the time of  this loss you could choose COBRA/State Continuation if available or an individual policy)
  2. Loss of affordable employer sponsored coverage – affordable is defined as your share of individual coverage costing you more than 9.5% of your income from your employer
  3. Divorce
  4. Reaching the maximum dependent age limit on your parent’s policy
  5. Expiration of your COBRA coverage
  6. Termination by the carrier of an existing individual plan-30 days to apply for this QE
  7. Loss of Medicaid or CHIP eligibility

*A permanent move that puts you outside of your current insurance company’s service area

*Becoming an American Citizen

*Leaving incarceration

IMPORTANT NOTES:  A Special Enrollment Period will not be given if you voluntarily terminate your coverage or your policy was terminated due to non-payment of premiums.

Medicare Supplemental and dental plans can be purchased at any time throughout the year.

Please call us to discuss your options if you have experienced a qualifying event.

Posted on by Melanie Epstein in Health Care Reform Leave a comment



Despite the government shutdown, the Affordable Care Act is moving full steam ahead.  Today is opening day for the individual purchasing exchanges.  In Maryland, the exchange is called Maryland Health Connection and is being run by the State.  The District of Columbia’s exchange is called DC Health Link and is being run by the District. Virginia’s exchange is being run by the federal government.  Melanie Epstein and Peter Vinton have completed the required trainings and are authorized to sell plans on the exchange and as always off of the exchange as well.    Individual plans outside of the exchange will be available for January 1, 2014 without medical underwriting.  If you are eligible for financial assistance, you must purchase your coverage through an exchange.    As you can imagine, there are still a lot of questions and confusion.  We will do our best to help you determine your options!

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One of the main provisions of the Affordable Care Act is the establishment of a health insurance marketplace called an exchange.  The exchange is a governmental agency set up in each state where individuals and small businesses (50 or less full/time equivalent employees for right now) can purchase health insurance from insurance companies regardless of any preexisting conditions.  Some individuals may qualify for financial assistance for the premiums via an Advanced Premium Tax Credit as well Cost Sharing Reductions.  Some businesses may qualify for a Small Business Tax Credit.  In order to take advantage of these subsidies, the health insurance must be obtained via the exchange.

The Affordable Care Act has put the responsibility on informing employees about the exchanges on employers subject to the Fair Labor Standards Act (FLSA) regardless of whether or not you currently have a group plan established.

Here is the link to the Department of Labor’s guidance regarding this required notice:

Pages 3 and 4 do a good job of explaining the requirements of the notice and links to the model notices are provided in Section E.  There are two separate notices, a Model Notice  for those employers currently sponsoring a plan and a Model Notice  for those that do not.

If you are currently sponsoring a plan, pages 1 and 2 should be completed with page 3 being optional.   You will notice on page 2 the question regarding whether or not your plan meets the “minimum value standard.”  This is a difficult and complicated actuarial calculation defined in the Affordable Care Act. There are no requirements for small businesses to offer minimum value coverage and a delay in penalties for large employers.    As a result, the answer to this question is for informational purposes only at this time to help the exchange qualify individuals that may be eligible for the subsidies.

At this point, CareFirst is the only carrier that has performed this calculation and has advised that all of their plans for groups up to 200 do meet the minimum value standard.  Therefore, if you are a CareFirst client, you can check this box confirming that your plan meets this standard.

All of the other carriers have been silent to date and we do not have indication that they will be providing this information.   In an effort to provide you with some direction, we contacted the Department of Labor/Employee Benefit Security Administration directly.  They indicated that the notice they provided was simply a “model” and employers could edit and answer that question as they see fit.     Here is an example of what you could use:  “we are unable to determine whether our current plan meets minimum value as our current insurance carrier has not provided us with this information.”

The notices are due to the employees by October 1, 2013.  Please call us if you have any questions.

Posted on by Melanie Epstein in Health Care Reform Leave a comment

New Maryland Health Insurance Exchange – 10 Facts

I attended the producer training this week for Maryland Health Connection, the state’s marketplace for individuals and small businesses (50 or fewer employees) to purchase health insurance beginning in 2014.    Here are the top 10 facts learned:

  1.  No more denials for preexisting conditions! – Beginning January 1, 2014, any individual with a pre-existing condition cannot be denied coverage when applying for health insurance.  This eliminates the entire medical underwriting process our individual clients have endured.  However, you must purchase the coverage during the annual open enrollment period or at the time of a loss of existing coverage.
  2. Premiums can only be based on your age, tobacco use, geographic location and family composition (that’s new!)  Health status of an individual or of employees of a small group cannot be used.
  3. Family composition rating:    Whether you are in a small group or an individual purchasing coverage and whether purchased from Maryland Health Connection or directly from an insurance company your rate will based on your age + age of your spouse + age of any of your covered dependents over age 21 + ages of your three oldest children.  This means that each employee in a small group will have their own rate.    Yes – those of you who have had your older dependents on your plan even though they are eligible for coverage through their own jobs as the rate was the same no matter how many children you had should reevaluate.  Give us a call to help you sort through this after October 1 when the new plans and rates will be available.
  4. Tobacco users can be charged 50% more.  This applies to individuals and well as members of groups.  It is unclear whether all insurance companies will be charging this tobacco surcharge.
  5. The rate categories have been narrowed – the buckets are individuals under age 21, those over age 64, and those between ages 21-64.   In this last category the ratio of the oldest to the youngest is 3:1.  This means that the highest rate cannot be greater than three times the lower rate.
  6. To take advantage of the small business tax credit or the advanced premium tax credit (APTC) which is financial assistance at certain income levels for individuals, coverage must be purchased through the exchange.
  7. If you are enrolled in an employer sponsored plan, regardless of the type of plan offered or cost of the plan to you, you are not eligible for the APTC.  On the contrary, if you have waived your employer’s group plan and you meet the other qualifications for the APTC, you will be eligible.
  8. Pediatric Dental must now be included in all plans that are offered outside of the exchange as an essential health benefit.  Within the exchange, the plans can exclude this benefit as it can be purchased separately.
  9. In-vitro fertilization and hair prosthesis benefits are additional essential health benefits that will be available on individual policies only.
  10. The Maryland Health Insurance Partnership premium subsidy plan for small businesses that has been available will be eliminated.  These businesses will need to apply for coverage through the exchange to see if they can qualify for the small business tax credit.  The Maryland Health Insurance Plan State Plus (MHIP+), MHIP Federal and MHIP Federal Plus will be eliminated as of December 31, 2013.  If you have any of these policies you will need to apply for coverage through the exchange.  We can help!

Please call our office if you have any questions on any of these facts and to review your individual situation.


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Health Care Reform for You Tool

Cigna has been very active communicating to us the many components of health care reform. They now have a great tool for anyone to use to learn how health care reform is helping all of us understand health care reform. Try it out!


Posted on by Melanie Epstein in Health Care Reform Leave a comment