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HORAN Health Benefits Compliance Blog

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

Wellness Program Incentives - Planning for 2019

 August 20 2018     Diane Cross
As employers plan their employee benefits and wellness programs for 2019, one thing is for certain – EEOC wellness incentive regulations remain uncertain. As mentioned in a previous blog post, EEOC regulations allowing a maximum wellness program penalty/incentive of 30% are vacated as of January 1, 2019 per the court’s ruling in AARP v. EEOC. Since the ruling, the EEOC provided a sta...

Association Health Plans - Final Rule

 August 7 2018     Shelly Hodges-Konys and Diane Cross
Now that the DOL has released the final rule regarding Association Health Plans (AHPs), employers are interested in its impact - particularly for small business. As mentioned in our prior blog post on the topic, AHPs allow small businesses to come together to purchase insurance. They are not new, and some AHPs have been in place for years. However, the final rule expands their function by providin...

Several Important Limits to Consider in 2019 Benefits Planning

 July 10 2018     Shelly Hodges-Konys
With so many considerations, it’s easy to lose track of regulatory requirements. Several benefit plan limits that employers should keep in mind during their renewal decision process include, High Deductible Health Plan (HDHP) limits, Health Savings Account Contribution Limits, Affordable Care Act (ACA) Affordability percentages, and ACA maximum out of pocket limits. Following is a summary of...

Reminder: PCORI fees due July 31st for Self-Funded Employers

 July 2 2018     Shelly Hodges-Konys
The deadline for paying the annual Patient-Centered Outcomes Research Institute (PCORI) fee to the IRS is rapidly 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 (u...

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...
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