Maryland is moving forward with health care reform. Open enrollment for the individual health insurance exchange begins October 1 and "connector agencies" are doing outreach and promotion across the state.
The small employer ("SHOP") exchange will not open for enrollment until Jan. 1, 2014, and the coverage mandate for large employers (50 or more) has been delayed until 2015. But small nonprofit employers may be eligible for tax credits even now if they provide qualifying coverage to employees, and the Affordable Care Act ("ACA") has notice and information requirements for most employers that take effect this Fall.
By October 1, all employers subject to the Fair Labor Standards Act ("FLSA") must provide a notice to their employees about the new Health Insurance Marketplace (the Exchange), informing employees that they may be eligible for a premium tax credit if they purchase coverage through the Marketplace, and advising employees that if they purchase a plan through the Marketplace, they may lose the employer contribution (if any) to any health benefits plan offered by the employer.
The U.S. Department of Labor has prepared alternate models for this notice, one for employers who offer, and one for those who do not offer an employer sponsored plan. There is no coverage mandate for small employers with 50 or fewer full-time equivalent employees. The Maryland Health Benefit Exchange is also preparing models that will be tailored for Maryland employers.
Employers are also required to provide employees with a standard Summary of Benefits and Coverage ("SBC") form explaining what their plan covers and what it costs. The purpose of the SBC form is to help employees better understand and evaluate their health insurance options. There is also a model for this at the Department of Labor website. Employers should contact their group plan issuers, who should compile and provide these SBC's. This may be similar to, but is a different form and requirement, than the 'summary plan description' that insurance plan administrators are already required to provide under ERISA.
The Maryland Health Connection is organizing a series of information forums for small employers about the pending launch of the SHOP exchange. Enrollment scheduled to open on Jan. 1, 2014 with policies taking effect March 1, 2014 or later. The forums will be held in each of the six "connector" regions, with dates being planned between mid-October and mid-November. Maryland Nonprofits will be a partner in promoting these programs. We have asked a number of potential conveners of local groups to join with the Exchange to assure that all nonprofit employers have an opportunity to learn more from the Exchange itself about how it may benefit their organizations and employees. Contact Henry Bogdan for more information.
The six listed connector agencies are also hoping that local nonprofits will assist them in getting information about the individual exchange to any of their clients or others they serve who may be uninsured or eligible for subsidies through the exchange.
A short listing of web sources for more information on Health Reform and health exchanges:
Maryland Health Connection - http://www.marylandhealthconnection.gov/
National Council of Nonprofits - http://www.councilofnonprofits.org/resources/resources-topic/affordable-care-act-faqs#now
Small Business Administration - http://www.sba.gov/healthcare
Department of Labor - http://www.dol.gov/ebsa/healthreform/index.html
Internal Revenue Service - http://www.irs.gov/uac/Affordable-Care-Act-Tax-Provisions-Home
