Employer Notices From The Health Insurance Exchange
July 8, 2016
If, in 2016, one of your customer’s employees went to the Exchange, purchased coverage and received a subsidy your customer may receive a notice. The notices we have seen are addressed to a company’s “Benefits Manager”. Remember, your customer’s employee should not be eligible for a tax subsidy if your customer made an offer of affordable, minimum value coverage. That said, some employees still may have gone to the Exchange, provided incorrect information and received a subsidy.
If your customer received a notice for an employee who was offered coverage, appeal immediately. For your customers that made an offer of affordable coverage that meets the definition of minimum value coverage standard, they should immediately appeal the determination to end the possibility of a penalty. If your customer received a notice for a part-time employee who was not offered coverage, it is important to confirm the hours the employee actually worked and provide that as background as to why an offer was not made.
The deadline for appealing the benefits determination is 90 days after the date of the notice. If your customer does not do this, they will be required to challenge the process further down the road after the IRS issues a penalty assessment.
Remember, your customer’s employee will have thousand$ of reasons to avoid paying back the subsidy… Your customer should therefore be ready with a comprehensive appeal including any documentation that the employee was offered coverage, any reasons that they were ineligible for coverage, etc.