self-funded
The reporting requirements of the Affordable Care Act (ACA) are quickly approaching. Employers subject to the Employer Mandate should prepare to submit Forms 1094-C/1095-C to the Internal Revenue Service (IRS) by April 1, 2024. Employers not subject to the Employer Mandate but who offer a self-funded plan, including level funded plans and Individual Coverage Health Reimbursement Arrangements (ICHRAs) should be prepared to submit Forms 1094-B/1095-B to the IRS by this same date.
“Mini-COBRA” is a term commonly used for states that have passed a law to require continuation of coverage rights for group insurance plans that are regulated by the state. Most commonly, Mini-COBRA applies to fully insured medical plans and Health Maintenance Organizations (HMOs). A handful of states also extend continuation of coverage rights to fully insured dental and/or vision plans, and one state (Minnesota) extends continuation of coverage rights to group term life insurance.
The U.S. Department of Health and Human Services (HHS) has announced that self-funded health plans will be exempt from the reinsurance fees after the first year. The recent announcement is expected to be published in a forthcoming document with other rule modifications.
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