Here’s the latest of this evolving situation. But from what we know now, this is the new way.
Spouse must be on payroll, if not already, then provide W‑4 & L‑4 at enrollment to indicate that they will be put on payroll. at anytime blue cross can request a copy of their suta as proof that one of the owners is an actual W‑2 employee.
Spouse does not have to appear as member of the LLC since they will be on payroll, still must provide copy of llc or corp paperwork proving ownership.
If enrolling a husband and wife and there are other employees not enroling, we must provide a copy of their suta indicating the other employees are not eligible, if enrolling only owners. In this situation neither owner has to be shown as a W‑2 employee.
If one of their children, or any other family member is on payroll, spouse does not have to appear on payroll, she/he can be shown as member of the LLC or director of corp, whichever is applicable. 100% family related groups are acceptable as long as at least one is a W‑2 employee.
No 1099 contract employees are eligible for coverage.
LLC or corp must file taxes through the business and if they can provide copies of their schedule k‑1 from the previous year’s filing, then no other payroll info will be needed.
Updated new business checklist is attached and these must be signed by the group leader on page 3 to submit with new business groups.
Guidelines for existing husband/wife groups
We suggest you begin to notify your H/W groups that Blue Cross will be contacting them directly for confirmation of eligibility. This action is ENTIRELY up to you as we have not determined WHEN Blue Cross will begin this process or HOW. They should speak with their CPA to assist them with compliance of above rules so they can maintain their existing group policy.
We ask that your groups start now to get into compliance and when information is requested that it be submitted through our office and we will forward to Blue Cross parties. Click the image below for the new checklist and the buttons for copies of a W‑4 and L‑4.
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