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HORAN Health Benefits Compliance Blog

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

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Tax Cut & Jobs Act – Individual Mandate Repealed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 ...

Charging Employees Different Premiums

 December 8 2017     Diane Cross
When setting premiums for employees, employers generally have a great deal of flexibility with this portion of plan design.  That said, some employers consider charging employees different premiums and when doing so, questions inevitably come up on whether or not employers can do this.  As with most aspects of administering employee benefits, there are important considerations that will ...

Qualified Small Employer Health Reimbursement Arrangements (QSE HRAs)

 November 30 2017     Diane Cross
Can we reimburse employees’ individual health coverage premiums?  This is a question we often hear from employers, especially small employers.  Previous IRS guidance says NO - prohibiting the reimbursement of individual premiums directly or indirectly, pre- or post- tax, through an HRA, a Section 125 plan, a Section 105 plan, or any other mechanism.  While that still holds tru...

Coming Soon: ACA Employer Mandate Penalty Notices

 November 17 2017     Diane Cross
Employers who were Applicable Large Employers (ALEs) for 2015 should be on the lookout for an Employer Shared Responsibility Penalty (ESRP) letter from the IRS before the New Year.  Under the Affordable Care Act (ACA), ALEs are required to pay a penalty if they fail to offer health coverage meeting minimum requirements to at least 95 percent (70 percent in 2015) of their full-time employees a...

You are a New ALE, Now What?

 November 9 2017     Shelly Hodges-Konys and Diane Cross
Since 2014, major provisions of the Affordable Care Act (ACA) have been in effect.  For impacted employers, requirements of the ACA may seem old hat.  But, small employers approaching 50 full-time employees for the first time may need a refresher on how being an applicable large employer (ALE) impacts their organization (see our previous blog post Time to Reassess Applicable Large Employ...

IRS Releases 2018 Health FSA Contribution Maximum, ACA 2017 Forms, and Updated PCORI Fees

 October 26 2017     Diane Cross
While 2018 may seem at a distance – it is quickly approaching.  For many employers, this means time for open enrollment, as well as upcoming reporting requirements, deadlines, and fee payments under the Affordable Care Act (ACA). Recently, the IRS has released important information for employers including: (1) the 2018 contribution maximum for Health Flexible Spending Accounts (FSAs); (...

The Latest on Healthcare from the White House

 October 13 2017     Diane Cross
Yesterday, October 12, 2017, was a busy day for healthcare efforts at the White House.  In the morning, an Executive Order (EO) was signed, Promoting Healthcare Choice and Competition Across the United States, followed by an announcement later that evening that subsidies for low income Americans under the Affordable Care Act (ACA) will be stopped.  We discuss details of each separately b...
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