HORAN Health Benefits Compliance Blog

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

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...

Cadillac Tax Delayed

 December 21 2015     Shelly Hodges-Konys and David Anthony
On December 18, 2015, President Obama signed the new tax and spending bill into law, funding federal government spending until September 30, 2016, avoiding the possibility of a government shutdown. Contained within the spending bill is a two year delay to the Affordable Care Act’s Cadillac tax provision. The new effective date to the Cadillac tax provision will be 2020. The Cadillac tax, ori...

Late Payment of the Transitional Reinsurance Fee

 November 23 2015     David Anthony
Recently, the 2015 Transitional Reinsurance Fee had its annual requirement for self-funded plans to submit information on their annual enrollment and schedule a payment of the Transitional Reinsurance Fee no later than November 16, 2015. In 2014 the fee per covered life was $63 and in 2015 the fee is $44 per covered life. Self-funded plan sponsors are required to report covered lives and make a fe...

Auto Enrollment Provision in the ACA Repealed

 November 4 2015     Shelly Hodges-Konys
The Bipartisan Budget Act of 2015, signed by President Obama on November 2nd, repealed the auto-enrollment requirement contained in the Affordable Care Act (ACA). The ACA originally included a provision requiring employers with 200 or more employees to automatically enroll full-time employees into a health benefit plan. This provision in the law left many questions for employers includin...
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