Anthem Continues Negotiations with Sutter Health
Although the termination date for the Sutter and Anthem agreement for commercial business was on December 31, 2018, the current agreement allows Sutter providers to remain available to members while negotiations continue past this date. Although you may have heard from Sutter that Anthem would send out letters on January 1, 2019, to HMO members with Sutter doctors to notify them that they’d be reassigned if an agreement had not been reached, Anthem has clarified that it has not issued those letters.
It’s their top priority during these negotiations to continue to protect consumers’ access to affordable health care. Dickerson will continue to keep you updated of developments in the negotiation.
CCSB Has Extended Their New Submissions Deadline
Covered California for Small Business has extended their January new submissions deadline to 1-11-19. For any questions, please contact your Dickerson Account Executive.
Kaiser Extends No DE& 9C with
Six or More Enrolling Promo
Kaiser has announced that it has extended its NO DE 9C with Six or More Enrolling* promo and four weeks of payroll through March 2019 effective dates. The original promo was announced in September 2017 for new small groups with effective dates through January 2018. Kaiser recognizes that many start-up businesses do not have six weeks of payroll for their employees. This relaxed criterion affords earlier enrollment for groups that may not have otherwise qualified and supports their ongoing campaign of being “easier to do business with.” For more information, please contact your Dickerson Account Executive.
ACA Reporting Update, Extended Deadline
Despite a court ruling by a federal judge in Texas that the Affordable Care Act (“ACA”) is unconstitutional, all ACA coverage and reporting obligations for employers remain in place.
The IRS has published final forms and instructions to help employers prepare for the upcoming ACA reporting deadlines.
The IRS has extended the due dates for 1095 forms C or B that go out to employees due March 4, 2019, instead of January 31, 2019. This does not change the due date for form 1094 that’s due to the IRS with copies of forms 1095 by February 28th (Paper Filing) or April 1st (Electronic filing with the IRS).
The IRS also extends “good faith compliance efforts” relief for 2018 in certain circumstance where incorrect or incomplete information was reported in good faith on a statement or return. The relief does not apply to a failure to timely furnish a statement or file a return. For additional information, see IRS Notice 2018-94.
Applicable Large Employers who had 50 or more full-time or full-time equivalent employees during 2017 are required to complete the reporting forms 1095-C and 1094-C. Self-funded plans with less than 50 employees are to complete forms 1095-B and 1094-B.
Below are links to the final forms and instructions on the IRS website:
· Form 1095-B, Health Coverage.
· Transmittal Form 1094-B to accompany Form 1095-B.
· Form 1095-C, Employer-Provided Health Insurance Offer and Coverage.
· Transmittal Form 1094-C to accompany Form 1095-C.
IRS ISSUES GUIDANCE ON QUALIFIED TRANSPORTATION FRINGE BENEFITS
The IRS has issued interim guidance regarding the treatment of qualified transportation fringe benefit expenses paid or incurred after Dec. 31, 2017. The new rules assist taxpayers in determining the amount of parking expenses that are no longer tax deductible. They also help tax-exempt organizations determine how these non-deductible parking expenses create or increase unrelated business taxable income.
A key part of this guidance is a special rule, enabling many employers to retroactively reduce the amount of their non-deductible parking expenses. Under this rule, employers will have until March 31, 2019 to change their parking arrangements to reduce or eliminate the number of parking spots they reserve for their employees. For details, see Notice 2018-99.
REMINDER OF INCREASED 2019 IRS LIMITS
The 2019 annual dollar limit on employee contributions will increase for various benefit plans on January 1, 2019. Listed below is a recap of the 2019 limits:
|Employer-sponsored healthcare FSA||$2,700|
|Employee health insurance expense of small employers||$27,100|
|Qualified transportation fringe benefit and qualified parking||$265 / month|
|Monthly limit for qualified parking||$265 / month|
|HSA limit for self-only coverage||$3,500|
|HSA limit for family coverage||$7,000|
|HSA catch-up contributions for 55+||$1,000|
|HDHP minimum deductibles for self-only coverage||$1,350|
|HDHP minimum deductibles for family coverage||$2,700|
|HDHP maximum out-of-pocket amounts for self-only coverage||$6,750|
|HDHP maximum out-of-pocket amounts for family coverage||$13,500|
Eligible long-term care premiums are based on age and are subject to the following limits:
|Age before the Close of the Taxable Year||Limitation on Premiums|
|40 or less||$420|
|More than 40 but not more than 50||$790|
|More than 50 but not more than 60||$1,580|
|More than 60 but not more than 70||$4,220|
|More than 70||$5,270|
The deductible and out-of-pocket limits for “high deductible health plans” for Medical Savings Accounts are as follows:
· For self-only coverage, a health plan that has an annual deductible that is not less than $2,350 and not more than $3,500, and under which the annual out-of-pocket expenses required to be paid for covered benefits do not exceed $4,650.
· For family coverage, a health plan that has an annual deductible that is not less than $4,650 and not more than $7,000, and under which the annual out-of-pocket expenses required to be paid (other than for premiums) for covered benefits do not exceed $8,550.
· The dollar total amount of payments and reimbursements for any year under a Qualified Small Employer Health Reimbursement Arrangement (QSEHRA) cannot exceed $5,150 ($10,450 for family coverage).
The annual limits for qualified retirement plans in tax year 2019 are below:
|401(k), 403(b) & 457(b) deferrals||$19,000|
|Catch-up 401(k), 403(b) & 457(b)||$6,000|
|Annual Compensation Limit||$280,000|
|HCE Compensation Limit||$125,000|
|Maximum Pension at age 62||$225,000|
|SEP Minimum Compensation||$600|
|Key Employee Limit, Officer Test||$180,000|
|IRAs for individuals age 49 & below||$6,000|
|IRAs for individuals age 50 & above||$7,000|
Employers should update their benefit plan designs for the new limits and make sure that their plan administration will be consistent with the new limits in 2019. Employers may also want to communicate the new benefit plan limits to employees.
GOVERNMENT CONTRACTOR MINIMUM-WAGE INCREASE
Effective January 1, 2019, Executive Order 13658 requires that the minimum wage rate that generally must be paid to workers performing work on or in connection with covered government contracts be increased to $10.60 per hour.
STATE COMPLIANCE UPDATES
Emergency Responders Must Be On-Call during Breaks
Under recently-passed Proposition 11, emergency medical technicians and paramedics in California must be reachable during their entire work shift. If an emergency responder is called out while on a break, the employer must either allow that worker to make up the break during their work shift or would owe the employee one hour of pay at the employee’s regular rate of compensation.
The new law also requires ambulance companies to provide emergency workers with specialized resources, including annual training on dealing with natural disasters and other emergencies as well as mental health education, counseling and services.
New Law Prevents Discrimination against Reservists
Effective January 1, 2019, Senate Bill 1500 extends protections against discrimination in employment to military reservists. It also prohibits places of public entertainment or amusement from refusing entrance to any members of the U.S. Armed Forces because they are wearing a military uniform.
Los Angeles Minimum Wage Increase
Effective January 1, 2019, the minimum wage rate for employers with 25 or fewer employees will increase to $11 per hour. The minimum wage rate for employers with 26 or more employees will increase to $12 per hour.
Sacramento Increases Minimum Wage
Effective January 1, 2019, the minimum wage rate in Sacramento will increase to $11.75 for employers with more than 100 employees. For smaller businesses with 100 employees or fewer, the minimum wage rate will increase to $11. Employers receive a credit of up to $2 per hour by providing qualified health care benefits.
For news on other state compliance updates, click here.