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CMS Extends the Deadline to Report Membership Data for the Transitional Reinsurance Contribution

On Friday November 14th the Department of Health and Human Services’ Centers for Medicare & Medicaid Services (CMS) announced an extension of the deadline for submission of plan membership data for the transitional reinsurance program (TRP). Employer/plan sponsors of self-funded plans were originally required to report membership by November 17th, 2014, but the filing deadline has now been extended to December 5th, 2014.

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Supreme Court to Hear ACA Case

On Friday Nov. 7th the Supreme Court announced they plan to consider challenges to the government’s policy of providing subsidies to individuals who purchase health insurance through Healthcare.gov, the federally run Marketplace. The case will be heard early in 2015, with a decision likely at the end of the Court’s term early in the summer of 2015.
Background

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Employer Can Not Pay for Employee’s Individual Health Insurance

In the most direct guidance released to date, the DOL has issued new FAQs that make it clear employers are not permitted to pay for the cost of individual health insurance for employees, even if the payments are made on an after-tax basis.

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Health Plan ID (HPID) Requirement Delayed

On October 31st  the Centers for Medicare and Medicaid Services (CMS) announced an indefinite delay in the Health Plans ID (HPID) requirements applicable to self-funded employer sponsored health plans. Officially described as an enforcement delay, the announcement means that large self-funded employers will not be required to obtain an HPID by November 5th, 2014 as originally required. No further information regarding a new deadline, or other changes to the HPID requirements, was contained in the announcement. 

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