This is a re-issued advisory reminding health plan sponsors that if you have administered your cafeteria plan in accordance with this guidance, make sure to execute a formal plan amendment by the end of the 2015 plan year (December 31, 2015, for calendar year plans).
On September 18, 2014, the IRS issued several pieces of guidance on pressing Affordable Care Act issues, including Notice 2014-55. Notice 2014-55 provides for two new permissible, mid-year cafeteria plan election changes. The first change is intended to allow employees who were expected to average 30 hours of service per week to revoke their election and elect other minimum essential coverage if they experience a change in employment status after which they are not expected to average 30 hours of service, even if they do not lose eligibility under the plan. The second change is designed to allow employees enrolled in a group health plan and eligible to enroll in the Marketplace to elect Marketplace coverage, either during a special enrollment period or during the Marketplace’s annual enrollment period (e.g., when the group health plan year is not the calendar year). Employers may immediately rely on this guidance.
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