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HORAN Health Benefits Compliance Blog

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

Wellness Programs: Notice Requirement

 December 8 2016     Shelly Hodges-Konys
As open enrollment comes to a close and employers have provided benefit disclosures in compliance with the ACA, ERISA, HIPAA, and the like, it is an ideal time to remind employers with wellness programs that there is a new disclosure requirement per the Americans with Disabilities Act (ADA). As part of the EEOC’s final rule on employer wellness programs issued earlier this year, employers t...

IRS 6055 and 6056 Reporting Delay: Forms 1095-C Filing Extension

 November 21 2016     Shelly Hodges-Konys
The IRS issued a Notice announcing an extension to the deadline for distribution of Forms 1095-C to individuals. After extensive pressure from the industry, the IRS has agreed to give employers a 30-day extension to this deadline for the 2016 calendar year filings only. This means that Forms 1095-C must be distributed to individuals no later than March 2, 2017. Under the Affordable Care Act, ...

2016 Election Results: President-elect Donald Trump and the ACA

 November 11 2016     Shelly Hodges-Konys
In light of the 2016 presidential election results, we are left wondering what we can expect moving forward especially as it relates to Health and Welfare Benefits. President-elect Trump ran on a platform of “Replace and Repeal” of the Affordable Care Act (ACA). However, the process to repeal and replace the ACA will take time and nothing will happen between now and the New Year. It is...

Transitional Reinsurance Program: Deadlines Approaching November 15th

 October 20 2016     Diane Cross
As a reminder, on November 15, 2016, the Affordable Care Act (ACA) Transitional Reinsurance Program (TRP) 2016 Annual Enrollment and Contributions Submission Form is due, along with the second payment of the 2015 Transitional Reinsurance Contribution if making payment in two installments. The TRP is a temporary program designed to stabilize premiums in the individual health insurance market a...

Employer Medicare Part D Disclosure and Reporting Obligations

 September 23 2016     Shelly Hodges-Konys
The Social Security Act requires plan sponsors offering prescription drug coverage to provide certain notices regarding the prescription drug coverage they offer. Medicare Part D Notices of Creditable or Non-Creditable Coverage must be updated and provided to Medicare eligible participants by October 14th. Notices to Medicare Part D-eligible individuals must, at a minimum, be provided prior to the...

ACA Section 1557 Non-Discrimination Rules

 September 7 2016     Shelly Hodges-Konys
On May 18, 2016, the Office of Civil Rights (OCR) of the US Department of Health and Human Services (HHS) published final regulations implementing non-discrimination rules under Section 1557 of the Affordable Care Act (ACA). These rules prohibit discrimination on the basis of race, color, national origin, sex, or disability in health activities and programs that receive federal funding from HHS. ...

Administering Reductions in Hours under the ACA Look-back Safe Harbor

 August 24 2016     Shelly Hodges-Konys
When an employer uses the look-back safe harbor to determine full-time employee status, an ongoing employee is considered a full-time employee through the following stability period. There is an exception to the general rule for employees who have an official change in position such that if the employee had been originally hired into the new position, the employee would not be reasonably expected ...

Responding to Marketplace Notices

 July 15 2016     Shelly Hodges-Konys
Our clients began receiving Marketplace subsidy notices in late June/early July from the Department of Health and Human Services (HHS) notifying them that they have an employee who applied for a subsidy through the Marketplace program.  These notices do not mean that an employer will automatically be assessed penalties under the Affordable Care Act's employer mandate (applicable to large...

PCORI Fee Filing Deadline Approaching July 31st

 July 12 2016     Shelly Hodges-Konys
As a reminder, under the ACA, all medical plans are responsible for paying the Patient-Centered Outcomes Research Institute (PCORI) fee to the IRS, based on the number of plan participants. If the plan is insured, the insurance carrier pays the fee on behalf of the policyholder. If the plan is self-insured, the employer/plan sponsor must file the Form 720 and pay the fee to the IRS directly (unles...

ACA Reporting Deadline - TODAY

 June 30 2016     Shelly Hodges-Konys
Today is the last day for applicable large employers to file Forms 1094-C and 1095-C with the Internal Revenue Service (IRS). The IRS has indicated that as long as employers have made a good faith attempt to comply with the filing requirements that they do not intend to assess penalties. Your return is filed, but is that enough? There are two components to a good faith effort at compliance with...
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