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With open enrollment beginning soon for many organizations, it is important for employers to be aware of the legal changes affecting health plans for 2016.To remain in compliance, employers should review and update their health plans as needed and communicate plan changes to employees in an easy-to-understand manner.

Employers should consider the following steps as they evaluate their health plans for 2016 (Note: Many rules apply only to non-grandfathered plans, so reviewing grandfathered status may be the first step):

  • Ensure that the plan’s out-of-pocket maximum (OOP maximum) does not exceed the Affordable Care Act’s (ACA) limits for the 2016 plan year ($6,850 for self-only coverage and $13,700 for family coverage).
  • Embed an individual OOP maximum in family coverage, if necessary.
  • Ensure that the OOP maximum for an HDHP does not exceed $6,550 for self-only coverage and $13,100 for family coverage.
  • Ensure that the plan complies with ACA insurance market rules, including eliminating pre-existing condition exclusions and providing coverage for clinical trial participants and a comprehensive benefits package.
  • Monitor IRS guidance on whether the health flexible spending account (FSA) limit will remain at $2,550 or increase for 2016.

Applicable large employers should review their measurement methods for determining full-time status for the purposes of offering health coverage, and they should test 2016 health plans for affordability and minimum value to avoid ACA employer penalties.
To inform employees of any plan adjustments, employers should communicate with them early on, and often. Using a variety of formats, such as in-person meetings and written materials, can help employees select a plan that will best meet their needs for the coming year.

Questions? Contact Sue Justice with Emery Benefit Solutions for guidance