The following Health Reform Checklist is intended to guide you through the general compliance requirements of t he Affordable Care Act (ACA) as you prepare now for 2015 and beyond. In general, these items apply to all employers.

1. The following Health Reform Checklist is intended to guide you through the general compliance requirements of
the Affordable Care Act (ACA) as you prepare now for 2015 and beyond.
In general, these items apply to all employers. Items marked with a ‘+’ only apply to employers with 50 or more
Plan Design and Notice Requirements
1. Grandfathered Health Plans
 Grandfathered Plans are exempt from certain market
provisions of ACA. Review the triggers that would cause
your plan to lose grandfathered status now and into 2015
to determine whether your plan still meets or will meet
guidelines.
 Make sure the Notice of your plan’s intent to remain
grandfathered is included in all plan materials.
2. Annual Limits on Essential Health Benefits
 Ensure your plan and plan documents have no annual
limits for essential health benefits (EHBs) for plan
years beginning on or after January 1, 2014.
8. 60-Day Advanced Notice of Benefit Changes
3. Review Waiting Periods for Health Plan Coverage
 Review all waiting periods for enrollment to ensure they
do not exceed 90 days (applicable to all health plans
renewing or after January 1, 2014). Certain restrictions
can apply, such as orientation period, 1200 hour require-
ment or the lookback requirement.
 Consider the impact on non-discrimination testing if you
have different waiting periods for specific classes of
employees.
4. Eliminate Pre-Existing Conditions Language
 Ensure that any pre-existing conditions clauses have been
removed from all health plans for 2014 plan years going
forward.
6. Amend FSA Plan Documents
 Consider whether to amend your FSA plan such that the-
annual indexed account limit ($2,500 for 2014) will auto-
matically adjust in conjunction with any IRS cost of living
adjustment (you must track and modify your open enroll-
ment materials).
 If elections are mistakenly made that are over the
$2,500 limit, the IRS has allowed for the additional
funds to be included on the employee’s W-2 as taxable
income for the year in which the plan ends.
 Are an employee and spouse both enrolled in their
employers’ health FSAs? If so, both may elect up to the
$2,500 maximum.
7. Summary of Benefits and Coverage (SBC)
 Ensure that all eligible new hires are provided SBC upon-
initial enrollment into the health plan.
 Ensure that SBCs are provided during open enrollment
or at least 30 days before renewal of coverage.
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 Provide written notice of any material modification of
plan terms or coverage that affects SBC content not reflected
in the most recently provided SBC, and that occurs other than
in connection with a renewal or reissuance of coverage. This
notice must be provided to plan participants no later than 60
days prior to the effective date of the change.
9. Notice Of Public Marketplaces (Exchanges)
 Ensure that notices are provided within 14 days of date
of hire. This notice must be provided to all employees,
without regard to whether they are eligible
for coverage under the health plan.
10. Cost Sharing and Out-Of-Pocket Limits
 For plan years beginning in 2014, the ACA imposes cost-share
restrictions on essential health benefits provided by non-
grandfathered group health plans. For 2014, the annual
out-of-pocket limits applicable to both insured and self
-funded plans offered through and outside the Marketplace
are $6,350 for single coverage and $12,700 for coverage
for more than one. In 2015, the out-of-pocket limits HHS
has proposed will be $6,600 for self-only coverage
and $13,200 for family coverage.
5. Wellness Program Incentives
 For 2014 and beyond, there is an Increased limit in
contingent (outcome-based or activity-based) incentives/
disincentives permitted in wellness programs from 20 to
30%; or up to 50% for tobacco-free programs.

2. Fees, Filings and Reporting for 2014
and Beyond
11. Patient-Centered Outcomes Research
(PCOR) Fee
 PCOR fees are paid once a year in connection with IRS Form
720, Quarterly Federal Excise Tax Return. Amount of fee: $1
per covered life for plan years ending after 9/30/12 and before
10/1/13. $2 per covered life (indexed) for plan years ending
after 9/30/13 and before 10/1/14.
 For insured plans, Form 720 is due by July 31st following
the close of the policy year from the insurer, who includes
the fee in premiums.
 For self-funded plans, Form 720 is due by July 31st of the
calendar year following the plan year end.
12. Transitional Reinsurance Fee
 There is an annual fee beginning in 2014 through 2016,
for all fully-insured and self-funded health plans.
 Annual fee beginning in 2014 through 2016, imposed on
all-sized fully-insured and self-funded group health plans.
Fee based on covered lives, payable by the insurer for fully-
insured plans or plan sponsor for self-funded plans. For 2014,
the contribution rate is $5.25 per covered life per month, or
approximately $63, annually. For 2015, the fee to be collected
is $44 per covered life.

15. Health Insurance Provider Fees
(Imposed on Insurers)
 An annual fee imposed on “covered entities” such as
insurers covering U.S. health risks. Assessed fees are
apportioned among all applicable insurers, based on a
ratio of net premiums for insuring U.S. risks during the
preceding calendar year as compared to the aggregate
net premiums for that same year. The Fee is assessed when
net premiums covering US risks exceed $25 million for the
previous year.
Covered entities include state-licensed health insurance
companies, federal or state-licensed HMOs, entities
providing health insurance under Medicare Advantage,
Medicare Part D, Medicaid, and self-funded multiple
employer welfare arrangements (MEWA).While employers
are not subject to this fee, insurers may pass some of
the cost on to policy-holders.
16. Federal Marketplace User Fees (Applies
to Individual and Small Group Market Only)
 In states where a state-based marketplace has not been
established (currently 26 states), a federal marketplace
is available to individuals and small businesses. Where
this is the case, regulations impose a monthly user fee
of 3.5% of premium spread across all qualified health plans
offered in the state by that insurer to help fund the
federal marketplace. A state Marketplace may assess a fee
as well. This fee is paid by the insurer.
13. Filings for ERISA Plans
 Unless an exception applies, certain group health plans
subject to ERISA are required to file a Form 5500 Annual
Report filing, due the last day of the 7th month following
the end of the plan year. A Summary Annual Report (SAR)
for ERISA plans is due on the last day of the 9th month
after the plan year ends to participants.
 Multiple Employer Welfare Arrangements (MEWAs) are
subject Form 5500 filings, and to an annual M-1 reporting
requirement which is due March 1.
Health Reform Checklist, Page 2
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
17. Certification of Compliance with Electronic
Transaction Requirements (Self-Funded Plans Only)
ACA modifies certain aspects of HIPAA electronic transaction
rules to require a controlling health plan (CHP) and any sub-
health plan (SHP) to obtain a unique health plan identifier
(HPID) through CMS Enterprise Portal. The CHP or SHP must
certify that it is in compliance with certain standards for
electronic transactions and operating procedures for purposes
of processing: 1) eligibility for health plan transactions;
2) health care claim status transactions; and 3) health care
electronic funds transfers (EFT) and remittance advice
transactions.
The CHP or SHP should work with its TPA to ensure compliance
with these processes.
Obtaining HPID:

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 Large health plans (annual receipts $5M+) must obtain
HPID by 11/5/2014
Small plans (annual receipts <$5M) must obtain HPID by
11/5/2015
All plans must use HPID by 11/7/2016
CHP with HPID obtained prior to 1/1/15 must certify
compliance by 12/31/15
CHP with HPID as of 1/1/15 must certify compliance by
1/1/16
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CHP Certification Schedule:
14. MLR Rebate (Imposed on Insurers and Payable
to Policyholders and Subscribers)
 Large group insured plans (over 100 employees) must
spend at least 85% of premiums paid on medical claims.
Small groups (100 or fewer employees) and individual
markets must spend at least 80% on medical claims. If
not, a rebate is owed to the policyholder and subscriber,
based on pre-established pools. Policyholders and subscribers
must be notified by September 30, 2014 (for 2013 reporting
year and all subsequent years).
.
18. Report Health Plan Aggregate Cost on W-2
 All employers filing 250 or more W-2 forms must report the
cost of health coverage (both employer and employee cost)
in Box 12 of the W-2, using Code DD. Employers issuing less
than 250 W-2 forms are exempt until further guidance is issued.
Reporting and paying the fee: Submit annual enrollment count
(based on first 9 months of year) to HHS by November 15th of
each year on form available via www.pay.gov. Reporting form
will auto-calculate contribution amounts and allow payments
to be made. Contributions paid in two installments: 1st install-
ment due within 30 days of invoice reflects actual reinsurance
contribution (plus HHS’s administrative costs); 2nd installment
will be invoiced in 4th quarter following the year of submission
and reflects amounts allocated to U.S. Treasury.

3. Shared Responsibility Employer
Preparation
19. Determine Whether You Are a Large Employer
- Do you have 50 or more full-time equivalent employees
(FTEEs)? Note, the IRC Section 414 control group rules
apply for purposes of determining employer size.
 Add your full-time employees and part-time employees
(add part-time together, then divide by 120, then divide
by number of months used) to determine this.
 Use special rules for counting seasonal workers.
May use any consecutive 6-month period in 2014 for
determining Large Employer status.
20. Large Employers (100 or more FTEEs), or
 Employers with between 50 and 99 FTEEs: Shared Res-
ponsibility rules do not apply until plan years beginning on
or after January 1, 2016, if employee size and plan design
is maintained as of 2/09/14.
Workforce size and hours worked must be maintained
Employer may not change plan year after 2/09/14
Employers with 100 or more FTEEs: Shared Responsibility
rules apply for plan years on or after January 1, 2015

21. Large Employers – Review Health Plan to
Ensure Affordability and Minimum Value
Standards
 Ensure that the employee’s contribution to premium does
not exceed 9.5% of household income (affordability standard).
 Choose one of these three methods of calculating:
 Form W-2 method;
 Rate of Pay method; or
 Federal Poverty Level (FPL) standard
 Does coverage meet at least 60% of the total allowed costs
of benefits expected to be incurred under the plan
(minimum value standard)?
 Minimum value calculator supplied by HHS
 Safe harbor plan design
 Actuary determination
23. Large Employers – How is a Penalty Triggered?
A non-deductible excise tax is assessed on large employers who do
not provide minimum essential coverage (MEC), or adequate or
affordable coverage to their full-time employees. Two types of
potential penalties:
 No Coverage Excise Tax Penalty [IRC Section 4980H(a)]:
If employer fails to offer MEC to minimum of 95% (70% for
2015) of its full-time employees (employees plus dependents
beginning 2015) for any calendar month and employs at
least one credit employee*, the excise tax penalty calculated
monthly as: Number of FTEs - 30 [-80 for 2015]
X $166.67** (= $2000/yr**).
 Inadequate or unaffordable Excise Tax Penalty [IRC
Section 4980H(b)]: If an employer offers health coverage
to at least 95% (70% for 2015) of its full-time employees and
employs at least one credit employee*, and coverage fails to
meet minimum value standard or is unaffordable, then
monthly excise tax penalty is the lesser of: Number of credit
employees multiplied by $250** (= $3000/yr**), or
Number of FTEs - 30 (-80 for 2015) X $166.67**
(= $2000/yr**).
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*A credit employee is one who works at least 30 hours per week and who
is eligible for a premium tax credit or cost sharing assistance for buying
insurance through a marketplace. **These penalties are indexed beginning in 2015.
ACA Provisions Beyond 2014/2015
24. Employers With 200 or More Employees Must
Provide Automatic Enrollment in Health Plans
 Awaiting further guidance on this provision.
25. Non-Discrimination Rules for Insured Plans
 Awaiting further guidance, but assume these will be
similar to the Section 105 self-insured rules.
26. Cadillac Tax – Excise Tax on Rich Health Plans
 A 40% non-deductible excise tax will be imposed on the
value of high cost employer sponsored health coverage –
awaiting further guidance on this provision.
Applies to employers with 50 or more full-time equivalent employees as defined by the law.
Health Reform Checklist, Page 3
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Employers (50-99 FTEEs) - What Rules Apply by
Employer Size in 2015?

To maintain its level of benefits, the employer must
continue its contribution toward single coverage (the
employer contribution must be maintained to at least
95% of its level as of 2/09/14).
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+
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22. Large Employers – Who Must Be Offered Coverage to
Avoid Excise Tax in 2015?
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Offer coverage to all employees scheduled to work 30 or more hours
per week or 130 hours per month by the first day of the 4th month of
hire (however, the waiting period requirements of the ACA must
be satisfied) to avoid the risk of excise tax.
Choose the monthly measurement method or the look back
method. If look back method is chosen, then:

The information contained herein is not intended to be legal, accounting, or other professional advice, nor are these comments directed to specific situations. The information contained herein is provided as general guidance
and may be affected by changes in law or regulation. The information contained herein is not intended to replace or substitute for accounting or other professional advice. Attorneys or tax advisors must be consulted for
assistance in specific situations. This information is provided as-is, with no warranties of any kind. CBIZ shall not be liable for any damages whatsoever in connection with its use and assumes no obligation to inform the
reader of any changes in laws or other factors that could affect the information contained herein.
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Establish a look back measurement/stability period to review
ongoing variable/seasonal employees in 2014.
Establish an initial look back measurement/stability period for
newly hired variable employees (those who may be seasonal, or
hired to work less than 30 hours per week, or individuals for
whom hours worked is not known at the time of hire). This
period may be between 3 and 12 months.
Establish a look back measurement/stability period to review
ongoing variable/seasonal employees in 2014.
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