HORAN Health Benefits Compliance Blog

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

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)...

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...
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