Changes

• Long Term Care – CLASS Program: Voluntary program for purchasing LTC (All ERs)
• W2 Reporting: Include cost of Group Health Plan coverage on W2s (All ERs)
• Automatic Enrollment: Employers with more than 200 F/T employees must automatically enroll all new hires in group health plans; employers may choose which plan to auto enroll; employees may opt out (ERs > 200 F/T employees)
• OTC Medicines (unless prescribed or insulin): No longer reimbursable expenses under FSAs, HSAs and HRAs
• HSA Distributions: Excise tax for unqualified distributions from HSAs increased to 20% (HSAs)
• Medicare Advantage Plans: Three year phase down of plans begins. Related industry fees
• New Tax: Annual $2.5B fee/tax on pharmaceutical manufacturers (up to $2.8B in 2019) (Pharmaceutical Manufacturers & Importers)
• Small Businesses: Wellness Grants. Wellness Grants available for eligible employers who do not currently have wellness program in place. (Small Businesses (less than 100 employees who work 25+ hours/week))

Employer Checklist

• Employers < 100 employees (working 25+ hours/week) with no wellness program in place, apply for wellness grants to establish program
• Prohibit healthcare FSA reimbursement of OTC medicines, unless prescribed or insulin
• Prepare to report cost of Group Health Plan on W2s (to be sent in 2012); calculate cost and modify payroll system
• Employers > 200 F/T employees, establish procedures to auto-enroll new hires, with opt out option
• Determine whether to participate in CLASS Act (Federal Long Term Care Program) through payroll deductions
• If receive Medicare Part D subsidy, determine impact of no longer receiving Medicare Part D subsidy and strategy to address
• Communicate higher penalty (20%) for withdrawal of HSA funds for non-medical expenses
• Develop cost mitigation strategies for impact of new pharmaceutical taxes and Medicare Advantage phase down
• Amend SPD Wrap and Cafeteria Plan Documents and distribute to employees