Ann:
Thanks for your informative reply.
So assume if a large employer offers a skinny MEC, and it is accepted by the employee, they are not available for credits in the Exchange, right?
If they do not accept the MEC, they still are not available for credits in the Exchange, for the employee turned down appreopriate employer-sponsored coverage, assuming it was affordable.
What do you think about the legality of offering solely a skinny MEC versus a skinny MEC, along with a fat plan?
It seems to me for an employer to offer a skinny MEC, he seems to avoid the penalty, but he does not allow the employee the option of going to the Exchanges and receiving subsidies whether the employee accepts or refuses the employer plan.
Don Levit
1st question - correct. If an employee ENROLLS IN the skinny MEC, even though it isn't adequate (60% actuarial value or more) or affordable, then the employee won't get a subsidy for the months that they are ENROLLED IN it. If they had never enrolled in it in the first place, or if they disenroll, then they may be subsidy eligible.
2nd question - correct. If the employer had offered this triad (skinny MEC + affordable/adequate plan + a richer plan), then the employee still doesn't get a subsidy because the 2nd plan choice was affordable & adequate. In fact, the employer might only want to offer the first 2 plan choices and not the richer plan. But sheeez, why not? Since the first plan (the skinny MEC) is designed to get out of Penalty A for not having insurance, and the 2nd plan (the affordable/adequate one) was designed to keep the Employer's contribution low but also avoid Penalty B, then why not offer a richer plan design for employees who want to "buy up" to it?
3rd question - If you offer solely a skinny MEC, you bypass Penalty A for not offering insurance. But you still might get stung by Penalty B for every employee who gets a subsidy, because your MEC is not adequate (at least 60% av). Depending on the employer's situation, this may be a good strategy. For instance, I talked to a restaurant who had more than 50 FTE's (full-time equivalents), but only about 45 actual full-timers. Since the penalties are only assessed on full-time employees, they felt that those 45 full-timers wouldn't get subsidies anyway. So, in essence, they faced no "penalty B".
Last sentence - true.
why is the gov't allowing small groups under 50 full timers to have to structure group offerings at a Bronze level but large groups, say (is it 50 or 100) or more have to offer lesser plans with the MEC but they comply? Less benefit rich plans than a bronze level plan, and bigger companies can sneak by the law with this? Makes no sense.
Because they passed the law without reading it?
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Glad I only sell Indy... You group people make my brain hurt
This makes my brain hurt, too. And since the large employer penalties have been delayed, I'm really done posting about it for now. Have too many other things to do.