USA: Alliant Compliant Fast Facts & FAQ – July 29 2016

The following information was provided by Alliant, Asinta’s partner in the United States.

Top 5 compliance issues going into 2017

· Wellness: Verify your clients’ wellness programs meet new EEOC requirements;

· Flex Credit/Cash in Lieu Plan Designs: Check flex credit plan designs so that they qualify as an employer contribution to coverage; Include cash in lieu payments (“opt outs”) in the cost of coverage where required. More discussion in our Alliant Insight.

· Non-discrimination rules: Consider whether your clients’ plans could be impacted by these rules, which could require coverage for gender reassignment services; (See attached e-mail)

· Mental Health Parity: Ensure no “red flag” designs exist based on the most recent guidance;

· New SBC Model: Remember to use the new SBC model document as of 4/1/17

A Note About ACA Reporting Vendors

As we mentioned in our staff training earlier this week, the compliance team has posted an updated – and shorter – ACA reporting vendor list. Remember, while we refer to this as our “preferred” vendor list, our account teams and clients are NOT required to use these vendors. This was generated simply so clients have a list of resources that have been vetted by our teams and found to offer compliant and effective services, and with whom we were able to negotiate favorable pricing. There are no doubt a number of other vendor options that could be considered, and may be preferable depending on your clients’ unique needs. Over time, we expect that the reporting vendor selection process will become a routine part of plan administration, much like selecting a cafeteria plan or COBRA vendor; but for now, we felt there was still a need for our teams to have some of this referral information on hand. Please contact your designated compliance team member if you have additional questions.

FAQ of the Week

Q. Are all full-time employees also ongoing employees?
A. No. An “ongoing employee” is an employee of an employer that uses the Look-back method to determine FT status who has been employed for at least one complete standard measurement period. A full-time employee that has not been employed for one whole measurement period is not considered an ongoing employee. Furthermore, an ongoing employee can also refer to a part-time employee that has completed one standard measurement period. An ongoing employee has the protection of the stability period. If an ongoing employee’s employment status changes before the end of a stability period, the change will not affect the classification of the employee as a full-time employee (or not a full-time employee) for the remaining portion of the stability period.

Thanks again to Alliant for providing us with this content!