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While Trump Administration shot down the idea of a special ACA enrollment period to help individuals who have lost their coverage due to the COVID-19 Pandemic, states that administer their own exchanges across the country have done the opposite and opened special enrollment periods. This could be especially beneficial for individuals in states that have instituted their own version of the Individual Mandate, such as California, where individuals get the added benefit of avoiding any penalties for 2020 for lack of coverage when they sign up during the special enrollment period.
California’s health insurance marketplace, Covered California introduced a special enrollment period as a result of the statewide Individual Mandate penalty that went into effect earlier this year. The exchange extended the special enrollment through June 30 in response to the COVID-19.
Covered California executive director, Peter Lee stated, “There’s no economic or public health rationale to not open the doors wide in the face of the pandemic,” according to an article by the New York Times.
California joins Colorado, Connecticut, Maryland, Massachusetts, Minnesota, Nevada, New York, Rhode Island, Vermont, Washington and the District of Columbia in allowing the uninsured and recently laid-off workers the opportunity to obtain health coverage.
Employers should note that with extended open enrollment periods coming into play, the likelihood of your employees receiving aact name Premium Tax Credit (PTC) is greater than ever. As a reminder, a PTC is a trigger to the IRS for initiating ACA non-compliance penalties, such as Letter 226J.
If your organization is not complying with the ACA’s Employer Mandate, you may be subject to significant IRS penalties under IRC section 4980H. The IRS is currently issuing penalties under section 4980H for the 2017 tax year through Letter 226J.
As a reminder to employers in conjunction with the Employer Shared Responsibility Payment (ESRP), the ACA’s Employer Mandate, Applicable Large Employers (ALEs) organizations with 50 or more full-time employees and full-time equivalent employees) are required to offer Minimum Essential Coverage (MEC) to at least 95% of their full-time workforce (and their dependents) whereby such coverage meets Minimum Value (MV) and is Affordable for the employee or be subject to Internal Revenue Code (IRC) Section 4980H penalties.
Employers may face challenges in their ACA compliance as a result of coronavirus COVID-19. If your organization needs assistance, contact us to see how ACA Complete can benefit you.
