Arlington, Va. – In a letter sent Thursday to President Barack Obama, RILA President Sandy Kennedy argued that the Administration’s failure in a timely manner to provide employers with formal guidance on the most basic of implementation rules for the Affordable Care Act (ACA) jeopardizes employer-sponsored healthcare coverage.
“RILA is extremely concerned that when formal guidance is finally released, employers will not have ample time to plan, budget and implement changes in order to comply with the new law,” said Kennedy.
While the law doesn’t take effect until January 2014, plan years beginning in early 2013 that transverse the ACA’s effective date are obligated to be in compliance. In some cases, the open enrollment period for such plans is under way now.
RILA raised similar concerns in a letter sent to President Obama in July. The association said it has engaged closely with the Administration in an effort to support and inform the complex rulemaking process. However, with no time left to reasonably comply with forthcoming implementation rules, transition relief is needed to allow employers to adapt existing benefits and design future benefits to comply with the law.
“RILA strongly urges the Administration to provide employers with transition relief with respect to the employer requirements under the ACA,” said Kennedy.
The letter included a sample of the many questions that employers need answered in order to ensure their health benefits comply with the new law.
The law is effective on January 1, 2014, yet there are no formal regulations for the employer requirements. How do employers with plan years that transverse January 1, 2014 comply, as 2013 plans are already in effect?
- How will full-time employees be defined?
- What is the definition of a seasonal employee?
- What does it mean to make an “offer” of coverage? How are employers expected to demonstrate that they have “offered coverage?”
- Who are “dependents?”
Click here to see the whole letter.