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COBRA Responsibility in Mergers & Acquisitions

 January 11 2019     Diane Cross
Business reorganizations, such as mergers and acquisitions (M&A), directly impact employee benefits administration – and one consideration is COBRA responsibility. What is our COBRA responsibility as a result of our business sale (or purchase)? is a common question we receive from employers. The short answer is, it depends on the circumstances, discussed further below.   W...

ACA Ruled Unconstitutional: What's the Impact?

 December 18 2018     Diane Cross
Last week, a federal judge ruled in Texas v. United States that the Affordable Care Act (ACA) is invalid. More specifically, the Court held that since the individual mandate penalty is eliminated (as of 2019), the entire ACA is unconstitutional. As expected, employers want to know what this means for their employee benefits administration.  For now, the ACA remains in place and employer...

ACA Reporting Update: Deadline Extended for Providing Information to Individuals

 December 10 2018     Diane Cross
Once again, the IRS (via Notice 2018-94) extended the due date for distributing forms 1095-C or 1095-B to individuals.  Originally due by January 31, 2019, self-funded employers and applicable large employers (ALEs) now have until March 4, 2019, a 30-day extension, to distribute Form 1095-C or 1095-B to individuals.  This is automatic and employers will not need to apply for this extensi...

Another Update from the IRS: FSA Contribution Limit Increase for 2019

 November 26 2018     Diane Cross
As anticipated, the 2019 maximum contribution limit for health flexible spending accounts (FSAs) is $2,700 (up $50 from $2,650 in 2018).  Recently, the IRS released annual inflation adjustments via Revenue Procedure 2019-57, which included an adjustment for FSAs.  For 2019, employees can elect up to a $2,700 salary reduction for contributions to their FSAs if their employers allow. ...

ACA Reporting for 2018: What's Changed?

 November 20 2018     Avery Ozimek
It’s again time for applicable large employers (ALEs) and employers who sponsor self-funded group health plans to prepare for reporting requirements under the Affordable Care Act (ACA).  For 2018, very little has changed from 2017. However small the change though, it is still important to understand the changes to properly comply and avoid penalties. (I know many employers are still hop...

IRS Releases Updated PCORI Fees

 November 12 2018     Diane Cross
Recently, the IRS released Notice 2018-85 providing the updated Patient-Centered Outcomes Research Institute (PCORI) Fee, which is adjusted for inflation annually. For health plan years that end on or after October 1, 2018 and before October 1, 2019, the dollar amount to calculate the PCORI fee is $2.45 per covered life (up from $2.39 for plan years ending on or after October 1, 2017 and...

Proposed Rules Expanding Health Reimbursement Arrangements

 October 29 2018     Diane Cross
Last week, proposed regulations expanding the use of Health Reimbursement Arrangements (HRAs) were released by the Department of Labor (DOL), Department of the Treasury, and Department of Health and Human Services (HHS). For reference, these proposed regulations are a result of President Trump’s executive order last October directing agencies to draft regulations that would allow for m...

Tips for Maintaining a Compliant Wellness Program

 October 5 2018     Shelly Hodges-Konys and Diane Cross
Recently, HORAN hosted a seminar on wellness programs and compliance.  Regulations surrounding wellness programs are quite complex, making compliance a “hot topic” for employers who administer a wellness program. To help maintain a compliant wellness program, we share our top five tips:  1.  Know What Type of Wellness Program You Offer To begin considering wellnes...

Medicare Part D Disclosure: Due to Medicare-Eligible Individuals

 September 21 2018     Diane Cross
As briefly noted in our blog post discussing notice requirements at open enrollment, the annual Medicare Part D Creditable Coverage Disclosure is due to individuals by October 14th.  As a reminder, 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 Services ...

Open Enrollment - Time to Prepare your Notices

 September 17 2018     Diane Cross
When administering employee benefits, there is no shortage of notice requirements – especially during open enrollment.  Federal regulations such as ERISA, the Department of Labor (DOL), Centers for Medicare/Medicaid (CMS), 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 whic...
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