HORAN Health Benefits Compliance Blog

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

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...

Cadillac Tax – Along with Other ACA Taxes – Delayed as Part of Reopening the Federal Government

 January 24 2018     Diane Cross
Earlier this week, President Trump signed a short-term spending bill (a Continuing Resolution, “CR”) to reopen and fund the federal government for the next three weeks.  Included in the CR are items that directly affect health benefits, with details below.  The CR, in addition to reopening the federal government, delays certain taxes under the Affordable Care Act (ACA). ...

Wellness Programs: Uncertainty with EEOC Incentive Maximums

 January 15 2018     Diane Cross
By now, many employers are familiar with the 2016 final regulations from the Equal Employment Opportunity Commission (EEOC) regarding wellness programs. As part of the final rules, employers were provided with welcomed guidance and clarification for designing compliant wellness program incentives. Specifically, the EEOC provides that wellness programs subject to the American with Disabilities Act...

ACA Reporting Update: Deadline Extended for Providing Information to Individuals

 January 2 2018     Diane Cross
In the final days of 2017, the IRS via Notice 2018-06 once again extended the due date for distributing forms 1095-C or 1095-B to individuals.  Originally due by January 31, 2018, self-funded employers and applicable large employers (ALEs) now have a 30-day extension until March 2, 2018 to distribute Form 1095-C or 1095-B to individuals.  This is automatic and employers will not nee...

Tax Cut & Jobs Act – Individual Mandate Repealed

 December 22 2017     Diane Cross
Today, President Trump signed into law the Tax Cut & Jobs Act that was passed by both the House and Senate earlier in the week.  While the Act brings significant change to the individual and corporate tax code, it also effectively repeals the Affordable Care Act’s (ACA) individual mandate.  This begs the question from employers, do we still need to report under the ACA for 2017...

Health Savings Accounts (HSAs) - Special Contribution Rule for Married Individuals

 December 19 2017     Diane Cross
This time of year brings holiday gatherings, New Year celebrations, and…2018 benefits planning.  While the latter may not be the best party banter, questions nevertheless come up regarding Health Savings Accounts (HSAs) specific to contribution maximums for the upcoming year.  For reference, our previous blog posts Health Savings Accounts (HSA) 2018 Limits Announced and 2018 HDHP ...
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