Horizon Brief Notes: Grandmothering Extended Into 2024 for Pre-ACA Plans

Applies to: Small Employer Market (4Q23 renewals)

Horizon will once again enable Small Employer group customers that offer health plans that preceded the Affordable Care Act (“pre-ACA plans”) and renew between October 1 and December 31, 2023, to renew within those pre-ACA plans. Because we receive the highest volume of renewals during the fourth quarter, this decision to grandmother pre-ACA plans will help make the renewal process easier for you and your clients.

If a group leaves its pre-ACA plan and meets eligibility requirements, it may move to an ACA-compliant policy with stand-alone pediatric dental (SAPD) coverage. Our popular ACA-compliant options include our OMNIASM Health Plans.

 As we near October 1, 2023, Horizon will communicate the details and dates for the renewal process. Until then, here’s what you can expect:

Group Communications

  • Pre-ACA renewals for October, November and December will include a renewal for the pre-ACA plan, an offer for a recommended ACA plan and the required CMS Model Notice.
  • ACA renewals for October, November and December will include the recommended ACA plan.
  • Renewals will be released according to the following schedule:
    • October renewals: by July 31
    • November renewals: by August 31
    • December renewals: by September 30

Groups with pre-ACA plans will automatically renew as is within the existing pre-ACA plans unless they actively select an ACA plan.

Pre-ACA to ACA Plan Conversions
All groups converting from a pre-ACA plan to an ACA plan are required to send in the conversion form, new certification paperwork, including applicable tax documentation as noted below, and waivers.

Mandatory Tax Documentation for Groups With Two to Five or 45+ Eligible Employees

The following requirements apply to all pre-ACA to ACA conversions regardless of whether they previously sent their certification to Horizon and were advised by Horizon Small Group Certification they could renew as is.

Group Structure Form Additional Documentation
Single Owner / Sole Proprietor Schedule C Q3 2023 WR-30 for employees
Partnership (must be 100% ownership) K-1(s) Q3 2023 WR-30 for employees
Corporate Entities (C- and S-corps) Schedule G for 2022 Q3 2023 WR-30 for employees
All Groups   NJ State WR-30:
Most recent completed quarter for all companies¹

WR-30 = Quarterly Wage Report

¹Effective October 1, 2023 and after, third quarter WR-30s will be required for fourth-quarter conversions.

Certification With Conversion Form and Waivers for Groups With Six to 44 Eligible Employees

Groups of six to 44 eligible employees do not need to submit tax documents. Instead, these groups need to submit the Certification with Conversion form and waivers.

If a group accepts its existing pre-ACA or ACA plan renewal, no paperwork is necessary. Conversion paperwork is only required if a group converts to a different ACA plan that was offered or if it moves from a pre-ACA plan to an ACA plan.

The conversion deadline for renewing groups or off-anniversary conversions is five business days prior to renewal date. Complete paperwork must be submitted in a timely manner. Incomplete paperwork may cause the group to lose their requested conversion date.

Certification Paperwork Submission

New certification paperwork, including waivers and tax documents as outlined above, is required with the conversion paperwork for groups of two to five and 45 or more eligible employees when converting from pre-ACA to ACA plans. This helps us ensure that husband/wife, sole proprietor and owner-only enrolled groups are renewing as is in their pre-ACA plans and are not converting to an ACA plan; these groups are not eligible for ACA plans.

Horizon sends certification paperwork to the broker or group at least 120 days prior to a group’s renewal. Groups are instructed to complete and return the paperwork to Horizon within 15 days of receipt. At that time, the group will have received its renewal information to decide to renew into the existing pre-ACA plan or move to an ACA plan.