CPS & Health Care Reform

Since 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.”)

Compliance Requirements for Employers

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

Watch "Explaining Health Care Reform: Summary of Benefits and Coverage"

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). 

Watch the Pay-or-Play webinar.

Watch the 1094 & 1095 Reporting Requirements webinar.

New Tax Reporting under the Affordable Care Act

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. 

Types of

Learn About Health Care Reform

Concordia Plan Services (CPS) will provide guidance to help employers:
  • Determine who is eligible for medical coverage through the CHP.
  • Determine exempt status regarding the contraceptive mandate of the ACA.
  • Review funding strategies to help employers be ACA-compliant
What’s Next for the ACA?

2020: The Cadillac Tax
  • ACA provisions allow an excise tax on the cost of health coverage exceeding a certain threshold.
  • A goal behind the tax is to reduce health care usage and costs by encouraging employers to offer plans that are cost effective and engage employees in sharing in the cost of care.
  • The tax is based on the total cost of each employee’s coverage that falls above predetermined amounts set by the ACA. The cost includes contributions paid by employers and employees:
    • In 2020, the tax is 40% of the cost of coverage that exceeds:
    • $10,200* for individual coverage and
    • $27,500* for family coverage
    • Amounts for future years will be indexed for inflation. Amounts are estimates referenced in the ACA and are subject to adjustments once 2020 is near.
Final guidance, including guidance for church plans, has not been released. However, Concordia Plan Services will continue to monitor the legislation and share information as it becomes available. CPS is evaluating the CHP benefit options and developing a strategy to minimize the impact of this ACA provision for LCMS ministries. A first step in this strategy is the introduction of new Concordia Health Plan options. 


Employer Shared Responsibility: To avoid penalties, employers with 50 or more full-time or full-time equivalent employees must offer coverage to eligible employees, and that coverage must be affordable and meet a minimum value. 

Affordable Coverage: For purposes of a worker’s eligibility for the premium tax credit, coverage is considered affordable if the worker’s share of the premium for self-only coverage does not exceed 9.5% of the worker’s household income. For purposes of the employer penalty, coverage is considered affordable if the cost of coverage does not exceed 9.5% of the worker’s W-2 wages (or as an alternate, the employer may use the rate of pay). The penalty only applies to large employers (those with 50 or more full-time or full-time equivalent employees). 

Full-Time Employee: The ACA defines a “full-time employee” as an individual who is scheduled to work an average of 30 hours or more per week. 

Essential Health Benefits:  The ACA requires health plans in the individual and small group market to provide certain benefits. All CHP options offer Essential Health Benefits. 

Minimum Essential Coverage: Coverage provided through employer-sponsored plans, certain government-sponsored plans (Medicare, Medicaid, CHIP, etc.), plans in the individual market, grandfathered health plans, and any other health benefits coverage (such as state health benefits risk pools) as recognized by the Health and Human Services (HHS) Secretary. 

Determining Your
Exemption Status

Walking Together 

As part of our commitment to walk together with you in mission and ministry, CPS continually reviews all released guidance and information, and determines how this additional information will impact LCMS employers and church workers. This information will also be passed on to you.

CPS evaluated the Health Insurance Marketplace model notices to determine how we may best assist employers. We have developed a modified Marketplace model notice template containing CHP-specific information as well as instructions to assist employers in fulfilling this notification requirement. LCMS employers in the CHP are able to use this template to add information, and distribute it to their employees.

Note: All employers are required to provide the Marketplace notice to all new hires, even if they do not offer health coverage. Employers offering coverage other than the CHP may want to check with their coverage provider for assistance in completing the model Notice or for a modified version of it.