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HORAN Health Benefits Compliance Blog

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

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)...

CMS Guidance on “Grandmothered” Health Plans

 April 6 2016     Shelly Hodges-Konys
Recently, CMS released guidance applicable to “grandmothered” group health plans (those employers in the 2-50 employee market that changed ERISA plan years and chose to early renew on December 1st in an effort to avoid community rating and other Affordable Care Act "ACA" market provisions). The announcement indicated that non-compliant plans will sunset in 2017 meaning that they will b...

New Proposed Summary of Benefits and Coverage (SBC) Template

 March 25 2016     David Anthony
It is hard to believe the Affordable Care Act was signed into law six years and two days ago, but who’s counting? Within that time many new provisions and requirements have taken effect, including providing plan participants a Summary of Benefits and Coverage (SBC). Although providing SBC’s to plan participants is not a new requirement, recently the Department of Labor (DOL) along with...

Maximum Out-of-Pocket 2017

 March 17 2016     David Anthony
The Department of Health and Human Services (HHS) has announced the new 2017 health plan out-of-pocket maximum amounts (MOOP). As a refresher, every year HHS sets an annual maximum dollar limit that caps the out-of-pocket expenses for individuals enrolled in single or family insurance coverage. For context, when an individual or family pays medical claims during the year, such as co-pays, deductib...

Employer Medicare Part D dislosure to CMS

 January 29 2016     David Anthony
As a reminder, The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 requires group health plans to disclose to individuals eligible for Medicare Part D whether the plan’s coverage is “creditable” (i.e., whether it is at least actuarially equivalent to the Medicare D coverage) or not. In addition to disclosing creditable or non-creditable status to Medicar...

ACA Employer Mandate Penalties 2015 and 2016

 January 19 2016     Shelly Hodges-Konys
With the buzz about the ACA’s employer mandate reporting provisions and the delay of reporting deadlines issued in late December, you may have missed the IRS’s guidance on the actual employer mandate penalties themselves. Remember, the ACA’s employer mandate contains two penalties that may be applied to employers with 50 or more full-time equivalent employees that fail to offer ...

ACA Employer Mandate Reporting Deadlines Extended

 December 28 2015     Shelly Hodges-Konys and David Anthony
The Internal Revenue Service (IRS) is keeping things interesting for employers, health coverage providers, and vendors by issuing a delay at what feels like the 11th hour. The IRS announced today that the due date for providing Forms 1095-B and 1095-C to individuals is extended from February 1st, 2016, to March 31st, 2016. The deadline for filing Forms 1094-B, 1095-B, 1094-C, and 1095-C to the IRS...

Health Insurance Provider Fee Delayed

 December 22 2015     Shelly Hodges-Konys and David Anthony
Last Friday, President Obama signed the new tax and spending bill that not only delayed the Cadillac tax, but also delayed the annual health insurance provider fee for one year starting in 2017. The annual health insurance provider fee is a provision within the Affordable Care Act (ACA) that requires health insurance carriers to pay an annual fee in proportion to the amount of net premiums they h...
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