PT/may Be Offered "skinny Plan", Subsidy?

[yorkriver1]

This prospect is a widow, working PT, COBRA about to run out, about $18K income for 2015. Employer just informed employees they can sign up with a company called National Enrollment System for "MEC preventive coverage" and/or a no hospitalization "Minimum Value Plan". No employer contributions as prospect understands the offer. Plans range from $15 to $22/week.
This means no subsidy, right?
So this employee, with diabetes and other health conditions is working for an employer who won't be paying penalties now. It also means buying a plan that is "affordable" but with no hospitalization coverage.
Wow. If this is true it will be hard to resist the suggestion to seek work elsewhere. It's home health aid work.

 

[bluediamond]

No Hospitalization? Yes, this person may be subsidy eligible. You say the employer is offering this coverage but with no contribution from employer, don't think that really constitute's the intent of the law as far as employer offering affordable coverage and to me (but someone else can chime in) the benefits don't measure up. There isn't enough information. Prescription coverage? Oh I would definitely run it through exchange.

https://www.healthcare.gov/fees-exemptions/plans-that-count-as-coverage/

I could be wrong according to the link. But we are going by the assumption that if there is no employer contribution this does not constitute employer offering coverage.

 

[taterpeeler]

rulling as of 11/4/14 mec with no hospitalization does not block client from subsidy

 

[Ann H]

rulling as of 11/4/14 mec with no hospitalization does not block client from subsidy

Peeler hit the nail on the head. HHS/DOL/IRS issued a combined ruling that these "no hospitalization" plans are not really MEC, and the employee can get a subsidy anyway. Of course, you have to check to see if there is another plan offered by the employer that is affordable/adequate, because many times these "no hospitalization" plans were just one of several plans being offered.

 

[yorkriver1]

Peeler hit the nail on the head. HHS/DOL/IRS issued a combined ruling that these "no hospitalization" plans are not really MEC, and the employee can get a subsidy anyway. Of course, you have to check to see if there is another plan offered by the employer that is affordable/adequate, because many times these "no hospitalization" plans were just one of several plans being offered.

OK, this is great! Will take some work. Prospect faxed me a one page summary of the two employer plans that are ACA related skinny plans. Here's the hospitalization exclusion statement: "Hospital inpatient, ambulatory surgical services, outpatient surgery physician, maternity benefits, organ transplants and specialty drugs are not covered services on this plan." This exclusion is from the more comprehensive plan of the two offered. Both include the statement they are set up to help employees avoid the ACA penalty (not to mention the employer, of course). The other of the two plans is for preventive and wellness benefits only.

Looks like this prospect's situation is subsidy eligible on Marketplace under the new ruling. If so, I doubt that a completed "Employer Coverage Tool" form will take care of the needed documentation. Reading the form found on HC.gov, it only asks if the employer plan meets the "Minimum Value Standard". The employer plan does, if we are asking about avoiding the penalty for employer and employee, but does not by the HHS/IRS/DOL standard Peeler and Ann mention. There is no place on the employer coverage tool form to indicate that hospitalization is not a covered benefit being offered. If that is so, then it's unlikely that the HC.gov subsidy application has a way to make an exception for, how shall we put it, "halfway" Minimum Value coverage. If we answer yes to "minimum value", then no subsidy.
The typical work around would be to just answer no to the questions that would kick the app out, like how HC.gov advised me to do with people losing employer coverage after the app date, so they could get SEP and subsidy.
For the "skinny plan" prospect, then, how to document in such a way to: a. get subsidy & coverage on HC.gov, b. avoid IRS issues at tax return time. Your input is gold here! Not sure if employer contributes on the skinny plan offers, but employee seemed to think they didn't. We can check if necessary.
So relieved to find out about the IRS joint ruling on these plans.
Without you all on here, I would have a much harder time with enrollment!