HORAN Health Benefits Compliance Blog

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

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...

EEOC Issues Final Rules on Wellness Programs

 June 1 2016     Shelly Hodges-Konys
Certain employer-sponsored wellness programs must comply with rules under the Health Insurance Portability and Accountability Act (HIPAA) and the Affordable Care Act (ACA). But if you will recall, based on recent complaints and court cases, employer wellness program design under HIPAA and the ACA and EEOC enforcement of ADA and GINA rules seemed to be at odds. New EEOC final rules on wellness pro...

ACA Affordability Safe Harbors for 2016

 June 1 2016     Shelly Hodges-Konys
As employers begin to develop strategies for renewal in 2016, we are starting to receive a lot of questions about affordability. Health coverage is considered “affordable” for purposes of the ACA’s employer mandate pay or play penalty, as long as the cost of single coverage under the lowest cost plan option that provides minimum value doesn’t exceed 9.5% of the employee&rs...

Finalized Summary of Benefits and Coverage (SBC) Template

 April 8 2016     David Anthony
Yesterday, several government agencies issued final regulations on the revised Summary of Benefits and Coverage (SBC). The newly revised SBC must be used for health insurers with plan years that have open enrollment periods starting on or after April 1, 2017. An SBC is a document that health plans and health insurance issuers (including fully-insured, self-insured, and grandfathered health plans)...
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