Change Is Coming - 2016 ACA Predictions
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Welcome to 2016! I’m always glad to turn the calendar over, and believe that change is good – it keeps things fresh, gives you a new perspective, and offers the hope of better things to come. But change isn’t always easy, especially at first. 2015 provided ample proof of that. The Affordable Care Act (ACA) drove change, not only on multiple levels, but consistently throughout the year – including a last minute change in the deadlines for what has proved to potentially be the most difficult requirement of all – the employer mandate reporting. We detailed the changes in our update, found here.
What does this mean for you, the employer? Just this: be prepared for more change in 2016. It’s an election year, so virtually anything can happen, but for what it’s worth, here are my employee benefit compliance predictions for change in 2016:
- The Cadillac Tax will be repealed. A risky prediction for 2016 – the budget deal reached at the end of 2015 delayed the implementation of the Cadillac Tax until 2020, the typical kick-the-can-down-the-road approach Congress likes to take with issues. However, it seems everyone wants to get rid of the tax, and the President is open to it. The time is ripe for it to happen, especially if it makes one or both parties look good for the election season.
- The new health plan non-discrimination rules will be revealed. It seems likely that the President will want to get all things ACA completed before he leaves office. Keep your eyes open for this one – depending on how these new regulations play out, they could represent yet another “game changer.”
- The ACA will be an election issue. I know, I know, this one is rather obvious, but remember: the rhetoric about the candidates say they’re going to do, and what they actually will be able to accomplish if elected are two completely different things. Early indications are that the Senate will probably flip back to the Democrats this time around, so Republican vows to repeal the ACA if they win the Presidency will likely not become reality.
- Reporting will become a bigger issue on the legislative front. Already, there are bills in Congress that would require the IRS to simplify the ACA’s reporting requirements, but they’re vaguely worded at this point. After the first round of reporting is actually done, the call by employers to Congress to make substantial changes to the reporting requirements should be loud and strong.
- The regulators will drop some totally unexpected guidance on some facet of the ACA that will take everyone by surprise. It happens every year, so this is an easy prediction to make.
We’ll check back in later this year to see how my predictions turn out. One thing I will say with certainty though – change will occur. I may have a wrong list, but that won’t stop change. Stay focused, and anticipate that what you do today may not be what you do tomorrow.
- Compliance Notice (12/28/2015) – Extension of Due Dates for 2015 Information Reporting
- 2016 ACA Playbook
- 2016 ACA Reporting Requirements Webinar Replay
- MEC and MVP Plans Take the Stand White Paper
- Compliance Support Page
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