HORAN Health Benefits Compliance Blog

Keeping you up-to-date and on-track with health benefits compliance

Medicare Part D Creditable Coverage Disclosure Due to CMS

 February 24 2017     Diane Cross
As a reminder, there are two disclosures required annually for certain employers related to Medicare Part D.  Employers with group health plans that provide prescription drug coverage to individuals that are eligible for Medicare Part D must disclose whether their drug benefit is creditable coverage to (1) individuals eligible for Medicare Part D and (2) to the Centers for Medicare & Medi...

President Trump's Executive Order and its Impact on the ACA

 January 23 2017     Diane Cross
As he promised, President Trump is continuing to demonstrate his commitment to repeal and replace the Affordable Care Act (ACA).  Shortly after his inauguration on January 20, 2017, one of President Trump’s first acts as president was signing an executive order, Minimizing the Economic Burden of the Patient Protection and Affordable Care Act Pending Repeal.  What does this exactly...

Senate Takes Major Step Forward in Repealing the Affordable Care Act

 January 12 2017     Diane Cross
The Senate took the first major step toward repealing the Affordable Care Act during a vote session that ended early this morning. As anticipated, the Senate passed a resolution for a reconciliation bill (budgeting tool), their first step in the repeal and replace process. Utilizing reconciliation provides the legislative tools necessary to repeal significant parts of the ACA. Republican leader...

New Law Permits Health Reimbursement Arrangements (HRAs) for Small Employers

 December 16 2016     Diane Cross
The New Year will bring additional celebration for small employers.  Beginning January 1, 2017, qualified small employers will once again be able to reimburse employees for their individual health insurance premiums.  President Obama recently signed the 21st Century Cures Act, which allows qualified small employer health reimbursement arrangements (QSE HRAs) to reimburse individual healt...

Phishing Email Disguised as official OCR HIPAA Audit Communication

 December 8 2016     Diane Cross
We would like to share the following information from the Department of Health and Human Services' (HHS) Office for Civil Rights with our clients sponsoring self-funded health benefit plans. As a reminder, HHS OCR is the entity responsible for auditing covered entities for compliance with the Health Insurance Portability and Accountability Act (HIPAA). Earlier this year, HHS announced its intentio...

Wellness Programs: Notice Requirement

 December 8 2016     Shelly Hodges-Konys
As open enrollment comes to a close and employers have provided benefit disclosures in compliance with the ACA, ERISA, HIPAA, and the like, it is an ideal time to remind employers with wellness programs that there is a new disclosure requirement per the Americans with Disabilities Act (ADA). As part of the EEOC’s final rule on employer wellness programs issued earlier this year, employers t...

IRS 6055 and 6056 Reporting Delay: Forms 1095-C Filing Extension

 November 21 2016     Shelly Hodges-Konys
The IRS issued a Notice announcing an extension to the deadline for distribution of Forms 1095-C to individuals. After extensive pressure from the industry, the IRS has agreed to give employers a 30-day extension to this deadline for the 2016 calendar year filings only. This means that Forms 1095-C must be distributed to individuals no later than March 2, 2017. Under the Affordable Care Act, ...

2016 Election Results: President-elect Donald Trump and the ACA

 November 11 2016     Shelly Hodges-Konys
In light of the 2016 presidential election results, we are left wondering what we can expect moving forward especially as it relates to Health and Welfare Benefits. President-elect Trump ran on a platform of “Replace and Repeal” of the Affordable Care Act (ACA). However, the process to repeal and replace the ACA will take time and nothing will happen between now and the New Year. It is...

Transitional Reinsurance Program: Deadlines Approaching November 15th

 October 20 2016     Diane Cross
As a reminder, on November 15, 2016, the Affordable Care Act (ACA) Transitional Reinsurance Program (TRP) 2016 Annual Enrollment and Contributions Submission Form is due, along with the second payment of the 2015 Transitional Reinsurance Contribution if making payment in two installments. The TRP is a temporary program designed to stabilize premiums in the individual health insurance market a...

Employer Medicare Part D Disclosure and Reporting Obligations

 September 23 2016     Shelly Hodges-Konys
The Social Security Act requires plan sponsors offering prescription drug coverage to provide certain notices regarding the prescription drug coverage they offer. Medicare Part D Notices of Creditable or Non-Creditable Coverage must be updated and provided to Medicare eligible participants by October 14th. Notices to Medicare Part D-eligible individuals must, at a minimum, be provided prior to the...
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