WIMPER Compliance Audit, Apex-MEC Preventive Care & Carrier Roster

1. Apex-MEC as the Clinical Preventive Engine: What Is on File?

Shielded Horizons LLC integrates Apex-MEC™ Clinical Preventive Care (underwritten in partnership with XGB Health / MultiPlan PHCS PPO Network) as the core clinical preventive and wellness infrastructure for participating employer groups. (Virtual urgent telehealth is also available as an elective modular add-on). Here is the exact clinical and compliance profile on file:

• ACA § 2713 & § 5000A(f) Compliant Minimum Essential Coverage (MEC): 100% coverage with $0 employee copay for 63+ statutory preventive health screenings, routine annual physicals, pediatric and adult immunizations, mammograms, colonoscopies, well-woman care, and standard preventive lab panels.
• National MultiPlan PHCS PPO Network: In-person clinical physician network across all 50 states, giving employees direct access to participating primary care physicians, certified clinics, and hospital outpatient diagnostic centers.
• ACA Employer Mandate Elimination (IRC § 4980H): Unlike standalone telehealth (which is an Excepted Benefit that provides 0% protection against Penalty A), Apex-MEC qualifies as Minimum Essential Coverage under IRC § 5000A(f), completely eliminating Penalty A ($2,970/worker/yr) for Applicable Large Employers (50+ FTEs).
• Statutory IRC § 213(d)(1)(A) Classification: Apex-MEC provides in-person physician examinations, diagnostic screenings, and laboratory assessments. This satisfies the statutory definition of medical care and completely insulates the plan from IRS Chief Counsel Advice (CCA) 202323006.
• ACA Participatory Wellness Safe Harbor: Confirmed under 42 U.S.C. § 300gg-4(j)(3)(c) and Federal Register 78 FR 33158. Participatory programs that don't condition benefits on health status outcomes are compliant per se.
• Elective 24/7 Virtual Urgent Care Add-On: Maintained as an optional modular add-on for employer groups requesting 24/7 middle-of-the-night bilingual virtual urgent care and mental health tele-counseling.

2. Do We Need a Separate Telehealth Vendor If Everyone Has Telehealth?

Answer: NO. Apex-MEC provides full statutory clinical preventive care, eliminating ACA Penalty A.

Because Apex-MEC delivers 63+ in-person clinical preventive health screenings under ACA § 2713, it fully satisfies IRC § 213(d) and eliminates ACA Penalty A. If employees or employers already have telehealth, virtual doctor access is 100% redundant and can be omitted to maximize employer margin and eliminate duplicate costs. No external third-party promoters are required.

3. The 3 Missing Pieces from Robert's Audio & How They Are Resolved

• Missing Piece 1 — Primary Beneficiary Designation Block: Manhattan Life $50,000 Guaranteed-Issue Group Term Life Insurance (under IRC § 79 & § 125(f)) requires capturing the employee's Primary Beneficiary (Full Name, Relationship, Phone, Email, Allocation %). We have built this dynamic block into both the general portal (index.html) and Chroma's portal (chroma.html).
• Missing Piece 2 — Annual Wellness Activity Agreement Checkbox: Under ACA regulations and IRS Section 105(b) rules, employees must affirmatively agree to complete at least one annual wellness activity (such as an online Health Risk Assessment or telehealth check-in) to maintain their tax-free SIMRP reimbursement status. If an employee refuses, the IRS requires treating reimbursements as taxable wages. We have placed this mandatory compliance checkbox directly in the digital intake form.
• Missing Piece 3 — Zero-Net-Pay Guarantee Banner & Corporate Documents: Hourly childcare staff ($13–$20/hr) need explicit reassurance that their take-home paycheck is 100% protected. Under Chroma's corporate Section 125 Cafeteria Plan and Section 105(b) SIMRP Plan Documents, the pre-tax salary reduction is offset dollar-for-dollar by the tax-free medical expense reimbursement, resulting in $0 net pay reduction (or a slight increase due to FICA savings). We have added prominent reassurance banners to the intake portals.

4. Final Carrier & Licensing Alignment Roster