Joshua Sutin, San Antonio
As head of Cox Smith's employee benefits/ERISA and tax practice groups, Josh Sutin assists clients with the challenges facing businesses today. Understanding that the scope of the Patient Protection and Affordable Care Act and its mandates can be overwhelming, the firm combined the talents of its employee benefits and health care attorneys into a PPACA team.
It's here. PPACA is here. It's staying. Get ready for it. The brokers out there who are learning about it and doing something will succeed.
Consider variables. Do you work with employers with variable hour employees? If so, have they thought about tracking their full-time status using the newSafeHarborrules for the “pay or play” mandate? They need to be preparing NOW and tracking hours ASAP in order to have the ability to lock these employees into full-time or part-time status for all of 2014.
Check your dates. Do you have customers with non-calendar year plans? Their deadline to comply with the “pay or play” rules may or may not be Jan. 1, 2014. Complex transition rules exist for non-calendar year plans—make sure your clients know which dates apply to them.
Wellness works. Wellness plans are a good thing, but PPACA has put many specific rules in place for rewarding employees. If your clients want to reward people based on certain health factors, they need to be very careful about compliance with the HIPAA nondiscrimination rules.
Associates only. If you're assisting customers with health plans, then the government considers you that company's business associate. The government has ramped up its HIPAA privacy and security requirements and expectations for business associates and you can get in big trouble for breaches. Business associates who deal with health plans must be very careful about how they handle customer data.
Photograph by Alexander Aleman
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