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Get Your Notices Ready...

 September 20 2019     Diane Cross
As many employers prepare for open enrollment, distributing required annual notices can be a tedious task on the to-do list. Federal regulations such as ERISA, HIPAA, and the Affordable Care Act (ACA) require employers to distribute various notices to employees, at specific times. Open enrollment is one of those times in which several notices are required to be distributed, as summarized below. ...

Medicare Part D Disclosure Due to Individuals

 September 9 2019     Diane Cross
With the bustle of open enrollment season, it is a good time to remind employers that the annual Medicare Part D Creditable Coverage Disclosure is due to individuals by October 14th.   Overview Employers with plans providing prescription drug coverage to individuals that are Medicare Part D eligible must disclose to such individuals and to the Centers for Medicare & Medicaid ...

Health FSAs: Impact on HSA Eligibility

 August 26 2019     Diane Cross
With open enrollment season upon us, the opportunity is ripe for individuals to decide to change elections to a High Deductible Health Plan (HDHP) and open a Health Savings Account (HSA). With that in mind, this is an ideal time to review the nuances of how Health Flexible Spending Account (FSA) coverage - specifically with a grace period or carryover provision - can impact HSA eligibility. &...

SPD vs. SBC: What’s the Difference?

 August 6 2019     Diane Cross
In an acronym heavy industry, it can be easy to confuse what documents plan sponsors are required to distribute and when. For example, both ERISA and the ACA require SPDs and SBCs, respectively, be provided to keep participants in the loop with what is happening with their welfare plans. Despite sounding so similar, ERISA’s SPDs and ACA’s SBCs are different documents that serve differe...

IRS Announces the Affordable Care Act’s Affordability Percentage for 2020

 July 25 2019     Diane Cross
The IRS issued Revenue Procedure 2019-29 this week announcing a decrease in the Affordable Care Act’s (ACA) affordability percentage for 2020 – 9.78% (down from 9.86% for 2019). In other words - this means that employer-sponsored group health coverage will satisfy the ACA’s affordability requirement under the employer mandate if the employee’s share of the lowest-cost, self...

IRS Expands Preventative Care Benefits Permitted to be Provided by HDHPs

 July 18 2019     Diane Cross
In response to President Trump’s recent executive order, the Treasury Department and the IRS expanded the list of allowable preventive care benefits that can be provided by a high deductible health plan (HDHP) before the deductible is met without impacting HSA eligibility. This welcomed guidance, effective immediately, provides much need clarity for employers, insurers, consultants and other...

President Trump’s Executive Order: Health Care Cost Transparency

 July 10 2019     Diane Cross
Recently, the “Executive Order on Improving Price and Quality Transparency in American Healthcare to Put Patients First” was signed by President Trump directing federal agencies to increase health care pricing and quality transparency – another major executive action impacting the industry. The order’s goal is to remove unnecessary barriers so that the health care pricing a...

Final Rule Expanding Use of HRAs

 June 17 2019     Diane Cross
Last week, a final rule expanding the use of Health Reimbursement Arrangements (HRAs) was released by the Departments of Health and Human Services (HHS), Labor (DOL), and Treasury (IRS). The rule, effective for plan years beginning on or after January 1, 2020, allows HRAs to be used for individual health coverage premiums and allows employers to offer an "excepted benefit HRA", as discussed below....

PCORI Fee Reminder: Due July 31st

 June 12 2019     Diane Cross
The deadline for paying the 2018 Patient-Centered Outcomes Research Institute (PCORI) fee to the IRS is quickly approaching. As a reminder, under the ACA, all medical plans are responsible for paying the fee. If the plan is fully-insured, the insurance carrier pays the fee on behalf of the policyholder. However, when it comes to self-funded plans, including health reimbursement arrangements (unles...

More Benefit Limits Released for 2020 – Increases for HSAs and HDHPs

 June 3 2019     Diane Cross
The IRS has recently announced annual limits for 2020, increasing the Health Savings Account (HSA) maximum contribution limitations and increasing both the minimum deductible and out-of-pocket maximums for High Deductible Health Plans (HDHPs). With so many considerations, it’s easy to lose track of regulatory requirements. Following is a summary of those limits for 2020. HDHP and HSA Li...
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