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Entries for 2019

IRS Expands Preventative Care Benefits Permitted to be Provided by HDHPs

 July 18 2019     Diane Cross
In response to President Trump’s recent executive order, the Treasury Department and the IRS expanded the list of allowable preventive care benefits that can be provided by a high deductible health plan (HDHP) before the deductible is met without impacting HSA eligibility. This welcomed guidance, effective immediately, provides much need clarity for employers, insurers, consultants and other...

President Trump’s Executive Order: Health Care Cost Transparency

 July 10 2019     Diane Cross
Recently, the “Executive Order on Improving Price and Quality Transparency in American Healthcare to Put Patients First” was signed by President Trump directing federal agencies to increase health care pricing and quality transparency – another major executive action impacting the industry. The order’s goal is to remove unnecessary barriers so that the health care pricing a...

Final Rule Expanding Use of HRAs

 June 17 2019     Diane Cross
Last week, a final rule expanding the use of Health Reimbursement Arrangements (HRAs) was released by the Departments of Health and Human Services (HHS), Labor (DOL), and Treasury (IRS). The rule, effective for plan years beginning on or after January 1, 2020, allows HRAs to be used for individual health coverage premiums and allows employers to offer an "excepted benefit HRA", as discussed below....

PCORI Fee Reminder: Due July 31st

 June 12 2019     Diane Cross
The deadline for paying the 2018 Patient-Centered Outcomes Research Institute (PCORI) fee to the IRS is quickly 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 (unles...

More Benefit Limits Released for 2020 – Increases for HSAs and HDHPs

 June 3 2019     Diane Cross
The IRS has recently announced annual limits for 2020, increasing the Health Savings Account (HSA) maximum contribution limitations and increasing both the minimum deductible and out-of-pocket maximums for High Deductible Health Plans (HDHPs). With so many considerations, it’s easy to lose track of regulatory requirements. Following is a summary of those limits for 2020. HDHP and HSA Li...

Forgot to Provide COBRA's Election Notice - Now What?

 May 23 2019     Avery Ozimek
Administering COBRA is ripe with complexities which can cause a variety of problems for employers. One COBRA requirement – providing qualified beneficiaries with their election notice within 14 days* of the notice of the qualifying event – tends to create room for error. Whether the employer forgets to provide the election notice, delays notifying its COBRA administrator, or there is ...

HIPAA Civil Penalties Decreased

 May 16 2019     Shelly Hodges-Konys and Diane Cross
It is rare to see “penalties decreased”, but here we have it and it is not a typo.  Late last month, the Department of Health and Human Services (HHS) released a notice applying a tiered annual limit to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) civil penalties.  The below is a summary of the new maximum penalties that all HHS HIPAA enforcement ac...

Final Notice of Benefit and Payment Parameters for 2020

 April 30 2019     Diane Cross
The Centers for Medicare & Medicaid Services (CMS) published its final Notice of Benefit and Payment Parameters for 2020 last week, which is issued annually and adopts changes for the next plan year.  This final rule primarily affects the individual market and the Exchanges, but also addresses various Affordable Care Act (ACA) provisions and related topics that impact employer-sponsored g...

Federal Judge Strikes Down Key Components of the DOL's Final Rule on Association Health Plans

 April 17 2019     Diane Cross
Recently, a federal judge invalidated two key provisions of the Department of Labor’s (DOL) final rule for Association Health Plans (AHPs).  Issued in 2018, the DOL’s final rule expanded the function of AHPs by allowing more small employers and individuals to join together and enroll in large group health insurance.  This provided small employers with a greater ability to gai...

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

 April 8 2019     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 2020 for those plans that have so far avoided community rating and other ACA...
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