By Scott Lyon, Senior Vice President
Before October 1, 2013, employers must notify their employees about the availability of the Health Exchange/Marketplace. In Michigan the Exchange will be called Mi Health Marketplace. In summary, this requirement applies to essentially all employers and requires you, as an employer, to provide the Exchange Notice to all of your employees.
Following are some frequently asked questions and the answers regarding this requirement:
- Which employers? With some very limited exceptions, all employers, regardless of the number of employees and regardless of whether or not you currently offer a group health insurance plan must provide the Exchange Notice.
- Which employees get the notice? Notices must be provided to all active full-time and part-time employees. Even if you do not currently offer a group health plan or, even if the employee has waived coverage if you do offer, they all must be notified.
- What does the notice have to contain? The Department of Labor has provided templates (one for companies that currently offer health insurance to their employees and a second for those that do not). We encourage our members to use the template. The notice must provide some general information about the Exchange/Marketplace and some specific information about your company. Further, the notice explains that employees can purchase health insurance from private insurance companies through a health insurance exchange known in Michigan as the Mi Health Marketplace. The notice must also describe the services provided by the Marketplace and explain how an employee can contact the Marketplace. We will provide this information to our members as soon as it becomes available.
- When does the notice have to be sent? Before October 1, 2013 is the short answer. Employers were originally required to provide this notice by March 1, 2013; however, because most all of the information required was not yet available, the deadline was delayed to October 1, 2013. For employees hired on and after October 1, 2013, notice of the Marketplace must be provided within 14 days of hire.
- How does the notice get sent? The notice must be provided in writing and delivered through first-class mail or through electronic delivery (for those of your employees who you know have the ability to receive electronic communications). Hint – keep copies along with the date of the mailing.
Sample Notice: As previously noted, the DOL has released two template forms that we encourage our members to use: one for employers who offer a health plan and one for employers who do not offer a health plan to some or all of its employees. Employers may modify the template to meet their needs and must include some employer specific information. The model notices can be found at: http://www.dol.gov/ebsa/healthreform/index.html.
Visit SBAM’s Decision Point for more details about the Affordable Care Act and what you as an employer need to do to be compliant.