Proposed ACA replacement legislation, entitled the American Health Care Act (AHCA), aims to dismantle the employer mandate by zeroing out the associated penalties. Despite this, the AHCA maintains both employer and insurer reporting requirements.
There are seven high-level changes to the current law that the AHCA will seek to impose:
- Nullify Individual Mandate Penalties
- Nullify Employer Mandate Penalties
- Repeal Cost-Sharing Subsidy for Out-of-Pocket Expenses
- Age-Based Qualifications for Premium Subsidies
- Rollback Medicaid Expansion by 2020
- Remove Limits on Health Savings Accounts
- Increase Price Ratios for Older Individuals
Beginning in 2018, the AHCA would effectively replace existing mandates with a “continuous coverage requirement,” which imposes a 30 percent premium surcharge for those who have coverage gaps in any given year for at least 63 continuous days.
The AHCA maintains the provision imposing the employer and insurer reporting requirements in order to administer various provisions of the law, such as the continuous coverage requirement. Reporting requirements will remain intact barring further legislative or administrative action.
In its current state, the AHCA would maintain the 1095 reporting and employee notice requirements in addition to the requirement for employers to report the total cost of sponsored coverage on each employee’s Form W-2. This legislation actually provides for additional reporting requirements that previously did not exist, such as an indication on the W-2 of which months each employee was eligible for group coverage – which is slated to take effect in 2020 in order to administer the advance payment tax credits.
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