HORAN Health Benefits Compliance Blog

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

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...

Draft Forms for 2018 ACA Reporting Available

 August 31 2018     Diane Cross
With the Affordable Care Act's reporting requirements (under Internal Revenue Code Sections 6055 and 6056) on the horizon, the IRS has released draft forms for reference.  While employers should become familiar with any revisions to the draft forms, the draft forms are provided as a courtesy and are not to be used or relied upon with filing.  Draft Forms: Draft 1094-B Form (Trans...

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...
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