Wednesday, March 4, 2015

Tax Penalty Special Enrollment Period (SEP) March 15 - April 30, 2015


It’s tax time and people who weren’t enrolled in a qualified health plan in 2014 are now experiencing the dreaded penalty (shared responsibility payment) on their tax returns.
The problem is, open enrollment ended February 15th.  Well, actually we had a special enrollment period (SEP) from February 16th- 22nd due to system issues that occurred because of the last minute high volume of traffic.  So what does one do now to prevent paying another penalty and an even higher one next spring for tax year 2015?

First let’s talk about SEPs.  The Affordable Care Act (ACA) and implementing regulations provide for special enrollment periods, triggered by certain events, which include, for example, life changes like marriage, loss of coverage or moving to a new state.  SEPs permit individuals to enroll in a qualified health plan outside of open enrollment.


The payment of 2014 taxes, due in 2015, was the first time anyone was subject to the Shared Responsibility Payment under the ACA.  So a new SEP from March 15 – April 30, 2015 was created based on the following guidelines.

This SEP is for consumers who:
1. Did not enroll in coverage for 2015 through the Federally-facilitated Marketplaces (FFMs);
2. Were subject to the Shared Responsibility Payment for 2014 ($95 or 1 percent of income, whichever is greater); and
3. Given that 2014 was the first year for such a requirement, first became aware of, or understood the implications of, the Shared Responsibility Payment after the end of open enrollment (February 15, 2015) in connection with preparing their 2014 taxes

I had a customer admit that she feels like she must have been living under a rock because she was clueless about open enrollment and the shared responsibility payment.  We have an appointment scheduled for March 15th.  And yes, if you look at a calendar, you’ll see March 15th is a Sunday.  In order to have an April 1st start date, you must enroll on the 15th, otherwise, you’re kicked to May 1st.
If you qualify for an SEP, whether it’s a life change or because you were unaware of the tax implications and had to pay a penalty for 2014, give me a call.  I can help.