This is one in a series of blog posts on the health-care law and the restaurant industry. The articles are written by Michelle Reinke Neblett, the National Restaurant Association's director of labor and workforce policy. This installment is the second of two parts.
In our last post, we highlighted a notice requirement many were or still may not be aware of: providing employee information about how to access an exchange.
In this post, we are focusing on two more requirements the Treasury Department is writing rules for now. One is the compilation of data and filing of a report by all employers subject to the employer mandate to the Internal Revenue Service. The second, likely, would be submitted by health insurance issuers for restaurants with fully-insured plans, however, sponsors of self-funded plans would be required to issue this report, too.
The first report must include:
1.????? The employer's name, date and identification number;
2.????? Certification that the employer offers their full-time employees and dependents the opportunity to enroll in an eligible employer-sponsored plan offering minimum essential coverage, including:
? length of waiting period
? months during the year coverage was available
? monthly premium for the lowest-cost option under the plan
? employers' share of the total allowed costs of benefits under the plan
3.????? By month, the number of full-time employees and dependents covered under the plan, including employee's name, address and tax identification number.
The second report would, like the first, include information about each individual insured and for how long. It also would feature:
? details about the coverage, including whether it was offered through an exchange;
? its applicable cost-sharing or premium tax credits; and
? the employer contribution towards the premium
Beginning, most probably, in 2015, both reports will have to be filed annually by Jan. 31. The same information also will have to be provided to each insured employee.
The reporting requirements are, without doubt, complex. They will necessitate the annual inclusion of health-care benefit data and individualized employee information. The NRA contends that the rules must be streamlined and contain flexible options that restaurants small and large can comply with.
The National Restaurant Association plans to submit comments to the Treasury Department and wants to know how you think the reporting requirements would affect your business. Email us at healthcarereform@restaurant.org.
The association is committed to your understanding of the law's requirements and its effect on your business. To understand the basics, visit the NRA's Health Care Knowledge Center. If you're interested in the regulations, visit our Health Care Policy page. We'll continue to keep you informed about current health-care implementation issues.
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