CPS & Health Care ReformSince the Patient Protection and Affordable Care Act (ACA) was signed into law, Concordia Plan Services has been devoted to understanding how health care reform will affect LCMS ministries and their workers, as well as the Concordia Health Plan (CHP). Our goal is to provide valuable, affordable, and competitive benefit programs that meet the needs of LCMS ministries and their workers – and to do so in a manner consistent with our faith.
- CPS Complies with ACA requirements that apply to church plans and organizations.
- CPS Provides guidance to employers in the Concordia Health Plan (CHP).
- We are here to help you follow the law, while still meeting the needs of ministry and upholding our Lutheran faith.
Grandfathered Health Plan: A grandfathered health plan is a plan that was in existence on March 23, 2010 (the date the ACA was signed into law), and has chosen to preserve the coverage and benefits that were in effect at that time, thereby only changing what is required by law or allowed within the guidelines of the law. (Note: CPS believes the CHP is a “grandfathered health plan.”)
Summary of Benefits and Coverage (SBC): SBCs must be provided to new hires, newly eligible workers, and upon initial or special enrollment, during open enrollment, 30 days prior to the start of each new plan year, and within 7 business days of requesting a copy. The SBC uniform glossary of terms must also be made available, either in print or only online. The government-provided template illustrates the general medical benefits and coverage provided by the health plan so that consumers can more easily understand their benefits and coverage. All SBCs are available in our plan documents.
Employer Shared Responsibility Mandate (Pay or Play): As of 2016, large employers (those with 50 or more full-time or full-time equivalent employees) may be subject to penalties if they do not offer minimum essential coverage, or if the coverage they offer is not affordable or does not provide minimum value (as defined by the government).
Marketplace Notice: Employers must provide this notice to any new employee within 14 days of their start date, and it may be provided by first-class mail or sent via e-mail if the Department of Labor’s electronic disclosure safe harbor at 29 CFR 2520.104b-1(c) are met. Concordia Plan Services has prepared a modified version (Modified Notice) of the Model Notice along with instructions for completing the notice for employers who offer the Concordia Health Plan. Part B (page 2) of the template requires each employer to complete items 3-12 with employer information and check the appropriate box indicating the number of hours the employer requires an employee to work to be eligible for health benefits. Part B - Page 3 is optional, but helpful for employees applying for Marketplace Coverage.