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HORAN Health Benefits Compliance Blog

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

IRS Keeps Employers and Participants with HSAs Busy Adjusting Contribution Limits

 April 30 2018     Shelly Hodges-Konys
In an effort to make sure that benefits professionals across the country stay busy adjusting health savings account contributions (HSA) for employees, the Internal Revenue Service (IRS) released guidance on Thursday afternoon applicable to 2018 HSA contribution limits.  The new ruling allows individuals with family high deductible health plan coverage to once again treat the originally announ...

Once Again - Transition Policy Extended for Non-ACA Compliant Health Plans

 April 20 2018     Diane Cross
Since 2013, the Department of Health and Human Services (HHS) has extended the transition policy for certain small employer health plans that do not comply with the Affordable Care Act (ACA). Per recent guidance from Centers for Medicare & Medicaid, health insurance issuers can renew non-ACA compliant coverage through 2019 for those plans that have so far avoided community rating and other ACA...

You've Received an IRS Employer Shared Responsibility Penalty (ESRP) Notice...Now What?

 April 13 2018     Diane Cross
As promised, the IRS has been issuing Affordable Care Act (ACA) ESRP Notices for the 2015 tax year via Letter 226J to employers believed to owe a penalty (see our previous blog post on the topic). As a reminder, under the ACA’s employer mandate, an ESRP can be assessed for 2015 if either: Minimum essential coverage (MEC) was not offered to at least 70% of full-time employees (and the...

Final Rule for Disability Claims Procedures Effective as of April 1st

 March 30 2018     Diane Cross
With the effective date approaching, employers have been asking questions about the final rule released by Department of Labor (DOL) providing new requirements for disability benefit claims. As of April 1, 2018, group health plans must comply with new procedural requirements when administering disability benefit claims. While this is no April Fool’s joke, there is good news for employ...

DOL Proposed Rules on Association Health Plans

 March 26 2018     Diane Cross
Earlier this year, the U.S. Department of Labor (DOL) published proposed rules that would expand Association Health Plan (AHP) regulations giving small businesses and sole proprietors more freedom to join together as a single ERISA-covered health and welfare plan. This would provide such employers with access to purchase health insurance in the large group market. While we typically wait to comme...

Deductible Carryover or Deductible Credit from a Prior Year & Health Savings Account Eligibility

 March 15 2018     Shelly Hodges-Konys and Diane Cross
This blog post has a mouthful of a title, but illustrates an issue that is nonetheless important – carrying over deductible expenses or giving deductible credit from a prior year (i.e. a deductible carryover) can impact Health Savings Account (HSA) eligibility. To be eligible to contribute to an HSA, an individual must be covered under a qualifying High Deductible Health Plan (HDHP) that op...

2018 HSA Family Maximum Contribution Decreased

 March 7 2018     Shelly Hodges-Konys and Diane Cross
This week, the IRS released IRS Notice 2018-10 which provides revised cost-of-living adjustments impacting Health Savings Account (HSA) contributions (and other issues). A provision of the Tax Cuts and Jobs Bill, enacted in the final weeks of 2017, changes the way the IRS calculates cost-of-living increases. As such, the IRS provided recalculated limitations, which has an impact on 2018 HSA cont...

Cafeteria Plans: Changing Elections Mid-Year

 February 20 2018     Diane Cross
Can I change my benefit elections? This question, or some similar variation, is all too common for employers to hear after the open enrollment period has ended. A response is not always a quick yes or no – per Section 125, which provides the rules for administrating a Section 125 plan (commonly referred to as a “cafeteria plan”), participant elections are generally irrevocable fo...

Section 125 Plan Nondiscrimination Requirements - Testing Early

 February 11 2018     Diane Cross
Some employers are beginning to receive Section 125 nondiscrimination testing requests from their third party administrators – and for some, this is just weeks after the start of the plan year. While true that the IRS requires Section 125 plans to be tested as of the last day of the plan year, it is important that these early requests are not shoved aside, forgotten, overlooked, or the dread...

Medicare Part D Creditable Coverage Disclosure Due to CMS by March 1st

 February 2 2018     Diane Cross
It’s that time of year for many employers to disclose Medicare Part D Creditable Coverage status to the Centers for Medicare & Medicaid Services (CMS).  As a reminder, there are two disclosures required annually for certain employers related to Medicare Part D.  Employers with plans providing prescription drug coverage to individuals that are eligible for Medicare Part D must d...
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