[MyOEBB] OEBB -- Notice of ACA Employee Group and New Bronze Plan Offerings

[MyOEBB system updates]

Dear Superintendents, Business Managers and Benefits Administrators:

As many of you may have heard, on April 28, 2015, the OEBB Board voted to offer a "Bronze Plan" option to assist OEBB-participating entities in complying with the Employer Shared Responsibility Provisions, or "pay" provisions, of the Affordable Care Act (ACA).

For plan years beginning in 2015, if an entity has at least 100 full-time equivalent employees (FTEEs), the entity must offer medical coverage to at least 70 percent of its employees who work an average of 30 hours per week (ACA definition of a full-time employee). This provision goes into effect October 1, 2015, for all OEBB-participating entities. The annual penalty for not meeting this requirement is $2,000 (prorated monthly) for each full-time employee of the entity (minus the first 80 full-time employees).

In most cases, employees working an average of 30 hours per week are in positions that qualify for benefits and a benefit contribution through a collective bargaining agreement or entity policy. The Bronze Plan option(s) cannot be offered to employee groups already established as benefits-eligible.

The Bronze Plan options meet the minimum essential benefits requirements under the ACA.  These options will only be made available to an entity that requests addition of the special employee group created for employees who meet the definition of a full-time employee under the ACA, but who are not eligible for a benefit contribution. This employee group will be limited to having medical coverage only (the Bronze Plan options); employee only or employee and child(ren) coverage levels; and the tiered rate structure. No other benefit coverages can be offered to employees who qualify for and are included in this employee group.

It is important to note that offering the OEBB Bronze Plan option(s) will not eliminate the entity's risk of penalties under the affordability provisions of the ACA. The premiums are lower than OEBB's other higher-deductible options, but without a contribution from the entity, an ACA full-time employee could still go to the marketplace (the exchange), apply for a medical plan and possibly qualify for a subsidy under the ACA. If the employee noted above does qualify for and enroll in subsidized coverage through a public exchange, the entity employing this individual could be responsible for ACA penalties related to offering unaffordable coverage. The penalty will be triggered if the required employee premium contribution for employee only coverage doesn't meet one of the three ACA affordability safe harbors:

*         9.5 percent of the Federal Poverty Level;
*         9.5 percent of W-2 Wages; or
*         9.5 percent of the employee's rate of pay

The annual penalty for not providing affordable coverage to ACA full-time employees is $3,000 per impacted employee (prorated monthly).

Because the parameters of offering this plan are so specific, and we expect the need and use to be limited, we are not posting the benefit summaries, rates, or forms on the OEBB website. The plan details and rates are attached for your information, as well as the attestation form (ACA Group Agreement) entities will need to complete and submit to OEBB if they wish to set up this special employee group in MyOEBB and offer the Bronze Plan option(s) to this particular group of qualifying employees.  If your entity wishes to add this new employee group for the 2015-16 plan year, complete the attached ACA Group Agreement form and send your request via email to OEBB.benefits at oregon.gov<mailto:OEBB.benefits at oregon.gov> or via fax to 503-378-5832. OEBB staff must authorize and create this ACA employee group in the MyOEBB system and will monitor this group for appropriate use on an ongoing basis.

If you have any questions about the Bronze Plan option(s), or which employees may qualify for coverage under this plan, please call OEBB Member Services at 888-469-6322, or send an email to OEBB.benefits at oregon.gov. You can find more information about the ACA provisions at: http://www.oregon.gov/oha/OEBB/Pages/HealthCareReform.aspx


Sincerely,

Denise L. Hall
Denise L. Hall, Deputy Administrator
Oregon Educators Benefit Board
http://egov.oregon.gov/OHA/OEBB<http://egov.oregon.gov/DAS/OEBB>

OEBB encourages all members to stay healthy and be happy!!!!     Pass it on.....
http://www.oregon.gov/OHA/OEBB/pages/welllinks.aspx




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