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Federally-Facilitated Exchanges to Notify Employers of Employees with Premium Tax Credits in 2017

Employers may receive notices from the Federally-Facilitated Marketplace (FMM) for employees with premium tax credits during the marketplace coverage year.

 

When will the notices be sent?
These notices are expected to be sent after the close of the marketplace enrollment period after each coverage year.

 

What purpose do these notices serve?
These notices are meant to allow an employer to prepare for any penalties that may be assessed as a result of an employee using a tax credit for marketplace coverage. They also give employers an opportunity to appeal the employee's eligibility for the tax credit.

 

What does it mean if I receive a notice?
Receiving a notice doesn't automatically mean you will pay a penalty. You have a ninety (90)-day window to appeal the notice if you do not agree the employee should have qualified for the tax credit.

As a reminder, an employer that is subject to the employer mandate may be subject to penalties if they did not offer coverage to their full-time employees and employees' dependent children (or the employer offered coverage that was not affordable and/or didn't meet minimum value) and an employee goes to the marketplace and qualifies for a tax credit and uses it to enroll in coverage.


Will employers receive notices for all exchange coverage their employees may enroll in?
No, the FFM notice applies to employees who apply for coverage and qualify for tax credits through healthcare.gov only. States may have their own processes for alerting employers of employees who receive tax credits through a state run exchange.

 

It is important to note that employers will only receive the notice if their employee has provided the employer's address when they enrolled in coverage.

 
How does an employer appeal the notice?
The employer appeal request forms can be found on
this website. The appeal form is sent to Health Insurance Marketplace, 465 Industrial Boulevard, London, KY 40750-0061 or faxed to 877-369-0129

 

If you have any questions, please contact your client solutions team.

 

This content is being provided as an informational tool. It is believed to be accurate at the time of posting and is subject to change. It is recommended that plans consult with their own experts or counsel to review all applicable federal and state legal requirements that may apply to their group health plan. By providing this information, Meritain Health is not exercising discretionary authority or assuming a plan fiduciary role, nor is Meritain Health providing legal advice.