K B Squared Your Human Resources Partner How do you keep up with HR trends, news and benefits administration information? Never miss a beat with our benchmark information, news on legislation changes and open enrollment information. Our up-todate documents will save you time and keep you in the loop. Are you compliant with current HR laws? Our legislative materials can help you stay in compliance with COBRA, FMLA, Health Care Reform, ADA and more. Is your employee handbook up-to-date? No need to worry about communicating company policies and procedures to employees; we have an employee handbook and individual employment policies to get you started. 1040 West Marietta St. NW, Atlanta, GA 30318 © 2014, 2015 Zywave, Inc. All rights reserved. (404) 662-2185 http://www.KB2benefits.com Sample Documents Table of Contents Educational Resources Health Care Reform: Pay or Play Penalty – IRS Examples for Determining Full-time Status ..3 Health Care Reform: What Does it Mean for You?.......................................................................4 Compliance Steps for the Final HIPAA Rule ................................................................................5 Avoid 10 Common ADA Mistakes .................................................................................................6 Preventing Turnover in the Workplace .........................................................................................7 HR Q&A: COBRA Notification Requirements - Employer Responsibilities ...............................8 Employer Tools Benefits Buzz Newsletter ...............................................................................................................9 Employee Handbook Checklist ...................................................................................................10 Employee Handbook ............................................................................................................ 11 - 12 Total Compensation Statement Packet .............................................................................. 13 - 14 Employee Videos ..........................................................................................................................15 Brought to you by K B Squared Pay or Play Penalty—IRS Examples for Determining Full-time Status Under Section 4980H of the Affordable Care Act (ACA), applicable large employers (ALEs) may be subject to a penalty if they do not offer health coverage to their full-time employees (and dependents), or if they offer coverage that is unaffordable or does not provide minimum value. Employers with 50 or more full-time employees, including fulltime equivalents, on business days during the preceding calendar year are considered ALEs. The employer shared responsibility rules were set to take effect on Jan. 1, 2014. However, on July 2, 2013, the Treasury delayed the employer mandate penalties and related reporting requirements for one year, until 2015. Therefore, these payments will not apply for 2014. On July 9, 2013, the IRS issued Notice 2013-45 to provide more formal guidance on the delay. No other provisions of the ACA were affected by the delay. On Feb. 10, 2014, the Internal Revenue Service (IRS) issued final regulations on the ACA’s employer penalty provisions. The final regulations include transition rules to help employers come into compliance with the employer mandate. Under these rules, the employer mandate will generally apply to: ALEs with 100 or more full-time employees starting in 2015; and ALEs with 50-99 full-time employees starting in 2016. LOOK-BACK MEASUREMENT METHOD The ACA defines a full-time employee as an employee who is employed, on average, for at least 30 hours of service per week. The final regulations provide guidance on an optional safe harbor method for identifying full-time employees for purposes of calculating an employer’s potential liability for a shared responsibility payment. This method is called the “look-back measurement method.” To help explain the look-back measurement method for identifying full-time employees, the final regulations include numerous examples. The examples address the methods for ongoing employees and new variable hour, part-time and seasonal employees. EXAMPLE OF ONGOING EMPLOYEES Facts—Employer Z, an ALE, chooses to use a 12-month stability period that begins Jan. 1 and a 12-month standard measurement period that begins Oct. 15. Consistent with the terms of Employer Z’s group health plan, only employees classified as full-time employees using the look-back measurement method are eligible for coverage. Employer Z chooses to use an administrative period between the end of the standard measurement period (Oct. 14) and the beginning of the stability period (Jan. 1) to: Determine which employees were employed, on average, 30 hours per week during the measurement period; Notify them of their eligibility for the plan for the calendar year beginning on January 1 and of the coverage available under the plan; Answer questions and collect materials from employees; and Enroll those employees who elect coverage in the plan. This is a sample document provided by K B Squared and is for illustrative purposes only. 13 From Health Care Reform: What Does it Mean for You? How the health care reform law affects you varies greatly depending on your income, who you work for and many other factors. So what does it mean for you? Below is a list of how health care reform affects different groups of people. Everyone: Beginning in 2014, every individual must either have health insurance that meets minimum standards of coverage or pay a penalty when filing tax returns. The penalty in 2014 is 1 percent of your yearly income or $95 per adult for the year, whichever is greater. For children, the penalty is $47.50 per child, up to a $285 maximum per household. The penalty increases every year. In 2015, the fee will be 2 percent of income or $325 per person, whichever is greater. In 2016, it will be 2.5 percent of income or $695 per person, whichever is greater. After 2016, it will increase with inflation. Those who choose to pay the penalty and remain uninsured will still be responsible for 100 percent of the cost of their medical care. While the penalty applies to the vast majority of Americans, there are certain exemptions. Uninsured people will not have to pay a penalty if they: Are uninsured for fewer than three months of the year Have low income and coverage is considered unaffordable Are not required to file a tax return because their income is too low Would qualify under the new income limits for Medicaid, but their state has chosen not to expand Medicaid eligibility Are a member of a federally recognized Indian tribe Participate in a health care sharing ministry Are a member of a recognized religious sect with religious objections to health insurance Health care reform affects each American differently based on many factors. Elderly: The elderly now receive free preventive services under Medicare, including annual wellness visits and personalized prevention plan services. Once those with Medicare prescription drug coverage enter the “donut hole” coverage gap, they will be eligible for drug discounts and subsidies, until the donut hole is completely closed in 2020. Medicare beneficiaries earning $85,000 or more will pay higher Part B premiums until 2019. High-income individuals will also pay higher premiums for Medicare prescription drug coverage. Those with Medicare Advantage plans may lose some benefits or experience an increase in copayments. Employees of a large company: Employers with 50 or more employees will be required to provide health coverage that is affordable and provides minimum value, or pay a penalty. These rules take effect in 2015 for most large employers. Mid-sized large employers with 50 to 99 employees may have an additional year, until 2016, to comply with these coverage rules. This article is provided by K B Squared. It is to be used for informational purposes only and is not intended to replace the advice of an insurance professional. Visit us at http://www.KB2benefits.com.© 2013 Zywave, Inc. All rights reserved. This is a sample document provided by K B Squared and is for illustrative purposes only. 4 Brought to you by K B Squared Changes to HIPAA Rules: HITECH Act President Obama signed the Health Information Technology for Economic and Clinical Health Act (HITECH Act) into law on Feb. 17, 2009. The HITECH Act contained health information technology provisions and also made significant changes to the privacy and security requirements of the Health Insurance Portability and Accountability Act of 1996 (HIPAA Privacy and Security Rules). The general effective date of the HITECH Act was Feb. 17, 2010, but some provisions had varying effective dates. In addition, on Jan. 25, 2013, the Department of Health and Human Services (HHS) issued a final rule that implements many of the HITECH Act’s changes. The final rule became effective on Sept. 23, 2013. This Legislative Brief provides an overview of the changes made to the HIPAA Privacy and Security Rules by the HITECH Act. BUSINESS ASSOCIATES Prior to the HITECH Act, the HIPAA Privacy and Security Rules directly applied only to Covered Entities - health plans, health care providers and health care clearinghouses. Under the prior law, a Covered Entity’s Business Associates had to agree, through a Business Associate Agreement, to comply with certain requirements of the HIPAA Privacy and Security Rules, but were not directly governed by the regulations. The HITECH Act maintained the Business Associate Agreement requirement, and made a number of the HIPAA Privacy and Security Rules’ requirements directly applicable to Business Associates. For example, under the HITECH Act, Business Associates are required to: Comply with the minimum necessary standard so that when a Business Associate uses, discloses or requests protected health information (PHI), it must limit PHI to the minimum amount necessary to accomplish the purpose of the use, disclosure or request; Report breaches of unsecured PHI to a Covered Entity in compliance with the Privacy Rules’ breach notification requirements; and Implement administrative, physical and technical safeguards to ensure the confidentiality, integrity and availability of electronic PHI (ePHI) and adopt and implement policies and procedures for protecting ePHI. The HITECH Act’s requirements for Business Associates generally became effective on Feb. 17, 2010. The additional obligations must be incorporated into the Business Associate Agreement between the Covered Entity and Business Associate. Penalties for violations of the Privacy and Security Rules that formerly applied only to Covered Entities now apply to Business Associates as well. The HITECH Act also expanded the definition of Business Associate to include organizations that provide data transmissions of PHI to a Covered Entity (or its Business Associate) and require access on a routine basis to this PHI, as well as vendors that contract with Covered Entities to offer a personal health record to patients. These Business Associates must enter into Business Associate Agreements with the Covered Entities. This is a sample document provided by K B Squared and is for illustrative purposes only. 5 Brought to you by the insurance professionals at K B Squared Avoid 10 Common ADA Mistakes The ADA Amendments Act of 2008 broadened the definition of disability previously established by the ADA and effectively expanded the group of people who would qualify as disabled. The amendments put more pressure on employers to provide reasonable accommodations and created more potential liability for companies that are not in careful observance of the law. This article provides helpful guidance for employers to follow, as well as common mistakes to avoid. What Employers Can Do There are steps employers can take to protect themselves from liability and prepare their company in case of a future lawsuit. Keep Job Descriptions Detailed and Accurate It is important that job descriptions are kept up-to-date and include essential functions of a job. Remember that employers generally have a responsibility to reasonably accommodate an employee who cannot perform an essential function. However, an employer does not have to eliminate an essential function of a job position as part of a reasonable accommodation. Essential functions in a job description can be one factor in legally proving that the task is indeed essential to the job; these functions can include physical requirements like lifting or standing and stamina requirements like working long hours or weeks. Employers have specific responsibilities under the ADA; failure to adhere to these responsibilities can result in lawsuits and significant penalties. There are steps employers can take to protect themselves from liability and avoid common ADA mistakes. Develop an Accommodation Policy Creating and distributing a reasonable accommodation policy can demonstrate your commitment to honoring the ADA. The policy should direct all reasonable accommodation requests to HR rather than to supervisors, as HR professionals are better equipped to deal with the nuances and legal risks of handling these types of requests. Train Supervisors Even though you direct employees to HR, supervisors still need to know how to handle the situation if a reasonable accommodation is requested of them. They should not respond either yes or no to the request, regardless of how feasible it may or may not be, but should instead refer the situation to HR. In addition, supervisors must be trained to handle potential ADA situations that may arise during a job interview or in their daily work with employees. This is a sample document provided by K B Squared and is for illustrative purposes only. 6 This HR Insights is not intended to be exhaustive nor should any discussion or opinions be construed as professional advice. © 2011-2013, 2015 Zywave, Inc. All rights reserved. Brought to you by the insurance specialists at K B Squared Preventing Turnover in the Workplace Though employers may make assumptions as to why employees leave the company, many organizations do not truly investigate or understand why some of the best in their workforce choose to work for other companies. In fact, most workers leave their jobs because of miscommunications about expectations, broken promises or excessive workloads. To prevent turnover, you must first determine your current turnover rate. This will help you realize how many employees you are losing and by what means. To do so, divide the number of employees that were terminated or left the company voluntarily during one month by the number of employees who were working at your organization at the beginning of that month. Beyond this calculation, you should also examine how many employees are leaving your organization voluntarily. For that statistic, divide the number of employees who left your organization within one month for voluntary reasons by the number of employees who were working at your organization at the start of that same month. If your turnover rate is significantly higher than your voluntary rate, you are in good shape because your employees are not choosing to leave you; you are choosing to let them go. Seeking Closure Though employers may make assumptions as to why employees leave the company, many organizations do not truly investigate or understand why some of the best in their workforce choose to leave. In fact, many workers leave because of miscommunications about expectations, broken promises or excessive workloads. Retaining Your Valued Employees To retain those employees that are hard workers and good assets to your company, consider these recommendations: Tell your valued employees how important they are to your organization, and do it often. Curtail apprehensions about job security and explain how employees can have a future with your organization. Be honest with individuals who are not meeting your expectations. Promote a diverse workforce. In addition to race, gender, ethnicity and sexual orientation diversity, hire individuals of various ages, marital and parental statuses, educational backgrounds, personality types and communication styles. Then, encourage your employees to get to know one another to learn more about their coworkers. Create an environment in which employees are accountable for their work and job performance. This is a sample document provided by K B Squared and is for illustrative purposes only. 7 This HR Insights is not intended to be exhaustive nor should any discussion or opinions be construed as professional advice. © 2011-2013, 2015 Zywave, Inc. All rights reserved. Courtesy of K B Squared What are the employer’s responsibilities when a thirdparty administrator is handling COBRA notifications? Employers have the option of contracting with a third-party administrator to administer their Consolidated Omnibus Budget Reconciliation Act (COBRA) obligations; that third party is referred to as the plan administrator. The employer is required to notify the plan administrator in the event of any of the following: Employee’s death Employee’s termination of employment (other than by reason of gross misconduct) Employee’s reduction in hours Employee becoming entitled to Medicare Employer filing for Chapter 11 bankruptcy Employers are required to notify the plan administrator within 30 days of an employee experiencing a qualifying event. However, if the employer uses the delayed notice rule, where the COBRA maximum coverage period begins on the date of the loss of coverage, the employer must then notify the plan administrator within 30 days of a loss of coverage due to the qualifying event. A special rule applicable to multi-employer plans allows for a longer period of time within which the employer must provide the plan administrator with notice. These plans may choose uniform time limits for a qualifying event notice (or election notice) or have the plan administrator determine when a qualifying event occurred. Any special rules must be set out in the plan’s documents. The employer’s notice must provide sufficient information to enable the plan administrator to determine the following: Plan name Covered employee Type of qualifying event Date of the qualifying event (including date of loss of coverage) This is a sample document provided by K B Squared and is for illustrative purposes only. 8 DID YOU KNOW? Telemedicine programs are gaining popularity in the health care industry— however, the financial advantages are still unknown and the surrounding regulations have not been clarified. Benefits tips brought to you by K B Squared Telemedicine is a form of technologybased communication that allows doctors and patients to communicate without being in the same physical space. Many health care providers are implementing telemedicine programs in an effort to save time and resources, as well as to make obtaining health care more convenient for patients who face barriers such as not having access to transportation. November 2015 ACA Small Group Market Rule Repealed Employers Prepare For Cadillac Tax On Oct. 7, 2015, President Obama signed into law legislation that repealed the Affordable Care Act (ACA) requirement that every state’s small group market be expanded to include businesses with 51-100 employees. Previously, most states defined “small employers” as those with 50 or fewer employees. Sixty percent of employers say that their current health plans will trigger the Cadillac Tax when the tax goes into effect in 2018, according to a survey by The International Foundation of Employee Benefit Plans. The President signed the Protecting Affordable Coverage for Employees (PACE) Act following its passage in the House and the Senate, where it earned bipartisan support. The PACE Act eliminates the ACA requirement that state small group markets be expanded to include businesses with 51100 employees. However, the act also gives states the option to include businesses with up to 100 employees in their small group markets. This is a sample document provided by K B Squared and is for illustrative purposes only. The Cadillac Tax is a 40 percent excise tax on employers who offer high-cost health insurance plans to employees. Employers are taking steps to calculate whether their health plans will trigger the tax and making changes to their health insurance plans in order to avoid it, such as shifting costs to employees or implementing high-deductible health plans. Most presidential candidates are pushing for a repeal of the tax due to the fact that it will force employers to reduce benefits for employees. However, many economists believe it is an essential component of the ACA, as it will effectively slow rising health care costs. For help determining the financial impact of the Cadillac Tax on your organization, contact K B Squared today. © 2015 Zywave, Inc. All rights reserved 9 Employee Handbook Checklist (In Handbook Order) Included Policy Title and Description Needs to be altered by each employer X Welcome and Purpose — This document introduces readers to the handbook and informs them that following handbook policies is a condition of employment, but that the relationship is at-will. X At-Will Employment Statement — This document explains that employment can be terminated by either party at any time, and that there should be no illusion of a contractual agreement between employees and the Company. X X Mission Statement — This document explains the Company’s mission, details how superior employees are selected and gives an overview of how the Company intends to fulfill its mission. X X Employment Termination — This policy explains the different circumstances under which an employee may be terminated (resignation, termination or layoff), provides notice period expectations for employees who choose to resign, and details other situations that may result in termination. X Equal Employment Opportunity — This policy explains that the Company provides an equal employment opportunity to all individuals and values a diverse workforce. X I-9 Immigration Reform — This policy explains that the Company will only employ persons who are legally eligible to work in the United States, in compliance with the Immigration Reform and Control Act of 1986. X Code of Ethics Policy — This policy informs the employee of the Company’s Code of Ethics; it goes into detail on the Company’s prohibition of improper payments, political contributions, reporting to management, antitrust laws and exchange of information with competitors. X Complaint Policy — This document explains the Company’s goal to have open communication with employees and, with that, details how employees should go about voicing complaints or grievances. X Disciplinary Action Policy — While each employee’s relationship with the Company is at-will, and a disciplinary procedure is not followed in all circumstances, the Disciplinary Action policy explains the Company’s basic approach to discipline. Check for statespecific content X X This is a sample document provided by K B Squared and is for illustrative purposes only. 10 This is a sample document provided by K B Squared and is for illustrative purposes only. 11 Table of Contents Introduction ............................................................................ 5 Welcome and Purpose .................................................................................................................... 6 At-will Employment Statement ......................................................................................................... 7 Mission Statement ........................................................................................................................... 8 Employment Policies ............................................................. 9 Employment Termination ............................................................................................................... 10 Equal Employment Opportunity ..................................................................................................... 11 I-9 Immigration Reform .................................................................................................................. 12 Workplace Conduct ............................................................. 13 Code of Ethics Policy ..................................................................................................................... 14 Complaint Policy ............................................................................................................................ 17 Disciplinary Action Policy ............................................................................................................... 18 Drug-free Workplace Policy ........................................................................................................... 19 Harassment Policy ......................................................................................................................... 20 Sexual Harassment Policy............................................................................................................. 21 Standards of Conduct .................................................................................................................... 22 Violence in the Workplace ............................................................................................................. 23 Weapons in the Workplace ............................................................................................................ 24 Workplace Bullying ........................................................................................................................ 25 Employee Benefits ......................................................................................................................... 26 COBRA Benefits ............................................................................................................................ 27 Employer-offered Insurance .......................................................................................................... 28 Employment Taxes & Voluntary Deductions ................................................................................. 29 Time Away from Work ......................................................... 30 Communicable Disease Policy ...................................................................................................... 31 Contagious Illness Policy ............................................................................................................... 32 Federal Family and Medical Leave Policy ..................................................................................... 33 Funeral Leave ................................................................................................................................ 43 Jury Duty........................................................................................................................................ 44 Lunch and Rest Periods ................................................................................................................ 45 Military Leave................................................................................................................................. 46 This is a sample document provided by K B Squared and is for illustrative purposes only. 12 Prepared for: , This is a sample document provided by K B Squared and is for illustrative purposes only. 13 Total Compensation Statement 2014 Benefits Statement Dear Joe Smith: This personal benefits statement is a brief outline of the benefits provides to you. It summarizes each benefit and illustrates the significance of your benefits package as part of your total compensation. Please review the information carefully and direct any questions or concerns to Jane Doe at 414-444-5586. Personal Information: TOTAL COMPENSATION: $39,973.18 Employment Information: SSN\Employee ID: 088-88-8888 Date of Hire: January 1, 2002 Name: Joe Smith Annual Base Salary: $32,562.00 Address: 800 Langdon St. Job Title: Electrician City, State, Zip Madison, WI 53207 Benefit Name: Benefit Description: Medical UnitedHealthcare Choice Dental MetLife Dental Plan Vision Vision Service Plan Discount Card Employer-provided Short-term Disability Company Provided STD benefit equal to 60% of your weekly rate for maximum benefit period of 13 weeks Employer-provided Long-term Disability Company provided LTD monthly benefit begins after 90 days of total disability. Benefit equivalent to 70% of basic monthly earnings while disabled up to age 65. Employer-provided Basic Life & AD&D One times salary to maximum benefit of $100,000 Voluntary/Supplement Life No coverage Dependent Life Annual Cost: Employer Cost: Employee Cost: $4,684.42 $ 783.90 $ 360.88 $ 226.20 $ 0.00 $ 25.00 $ 125.10 $ 0.00 $ 210.20 $ 0.00 $ 174.10 $ 0.00 $ 0.00 $ 0.00 No Coverage $ 0.00 $ 0.00 Voluntary Long-term Care Base plan covers $1,000 per month facility for 3 years or $500 per month homecare for 6 years. $ 0.00 $ 0.00 Health Care Spending Account 2014 Contribution $ 0.00 $ 364.00 Dependent Care Spending Account Commuter Expense Reimbursement Account Paid Yearly Paid Yearly $ 0.00 $5,000.00 $ 0.00 $ 800.00 401(k) Plan Can elect to defer up to 25% of your income pretax. Company match is 50% of withholdings up to 4%. $1,302.48 $2,604.96 Profit sharing Determined annually by board of directors based on profitability $ 554.00 $ 0.00 $ 0.00 $ 650.54 Employee Stock Purchase Plan Shares of company stock can be purchased 2 times annually with a 15% discount (see plan document for more details). This is a sample document provided by K B Squared and is for illustrative purposes only. 14 The small group market requirement would have significantly impacted midsized businesses by requiring them to purchase employee health coverage in the small group market rather than the lessregulated large group market. It was expected that the additional regulations would reduce health plan flexibility and increase costs for both employers and employees. K B Squared Educational Employee Videos While many mid-sized businesses have taken advantage of Open Enrollment Video HSA Employee Video transition relief delaying This video is part of the Know Your Benefits This HSA video is part of the Know Your the change Benefits series and can be used in from theseries large and can be used to promote and group market clarify the Open Enrollment process at your conjunction with the HSA Guide. This video to the small organization. It explains the basic steps explains and promotes health savings group market, employees should take during Open accounts. the PACE Act Enrollment. provides permanent relief from the requirement. The Know Where To Go - Choosing the Benefits 101: Introduction to Department of Health and Right Health Care Provider Video Insurance Payments Video Human Services This Know Your Benefits video provides Educate your employees about health (HHS) had guidelines on when employees should head insurance payments, including premiums, previously to their doctor's office, visit urgent care or deductibles and copays. stated that take a trip to the emergency room. small group market regulations for mid-sized businesses This is a sample document provided by K B Squared and is for illustrative purposes only. would not be 15 enforced if mid-sized