Transition Relief for ALE (50-99) W/ Plan Yr Change

[BenefitsGuii]

Background: Employer HQ is in NY with a satellite office in MA. Total FTE 96. Same FIN. Both locations renew on different dates. 1/1 for NY and 4/1 for MA with local carriers. Each location individually community rated. In 2014 company decided to consolidate both locations to the local BCBS plan in NY w/ HQ and go Experience Rated and adopt the MA renewal date due to plan differences, premium savings north of 100K, and ease of administration. Changing the NY date caused less disruption since they were on a copay plan and the MA population had a plan with a $500/$1000 Deductible single/family. So, no deductible needed to be reset with the change. The decision to do this was made in November of 2013 prior to 1/1/14 renewal so the plan to consolidate could be communicated to employees in both locations. New plans for 4/1/14 w/ BCBS meet Min Value, Affordability and they offer to more than 70%. Employed fewer than 100 FTEs, did not reduce workforce or overall hours, and did not eliminate or materially reduce health coverage in 2014.

Question: According to PPACA ALEs that change their plan years after 2/9/14, to begin on a later calendar date are not eligible for the One-year Delay. Does this company need to Pay or Play in 2015 or are they still eligible for the Transition Relief until 2016? Thoughts??

 

[toddoxley]

My understanding and how we are operating with our groups is that groups with 51-99 FTE do not need to comply until 1-1-2016. All groups that are above 100 FTE must comply in 2015 at there renewal or 1-1-2015 if they have a calendar year plan.

See link below for good info:

Affordable Care Act Tax Provisions for Employers

Read carefully. Click on the link " Employer Shared Responsability Provisions"