Articles

PCORI Fee Increase

In Notice 2014-56, the IRS provided the new amount for the Patient-Centered Outcomes Research (PCORI) fees for plan years ending after Sept 30, 2014 and before Oct 1, 2015. The fee for such plan years is $2.08 (up from $2) multiplied by the average covered lives for the plan year. The carriers/insurers will pay the fee on behalf of fully-insured plans, but self-funded plans are responsible for paying the fee on behalf of any applicable group health plans.

Read more

Section 125 Rules to Recognize Two New Permitted Election Changes

Last Thursday, the IRS released guidance regarding current Section 125 rules that is likely to be well-received by most employers. The guidance permits two new permitted election changes (prospective revocations) to correspond with some unintended consequences created under the employer shared responsibility rules under Section 4980H and new coverage options available through the public Marketplace (Exchange).

Read more

Medicare Part D Notice Reminder: Deadline of October 14th

As you may recall, with the introduction of Medicare Part D prescription drug benefits, the Centers for Medicare and Medicaid Services (CMS) imposed certain notice requirements on employers. Employers are required to notify all Medicare beneficiaries of the “creditable” or “non creditable” coverage status of their prescription drug plan.

Read more

IRS Releases ACA Employer Reporting Instructions

The IRS has released draft instructions for the employer health plan reporting requirements contained in the Affordable Care Act (ACA). Applicable large employers, and small employers who offer self-funded plans, now have the information they need to start planning for the required reporting beginning in 2016 for 2015 health 

Read more

Supreme Court Supports Innovation

In what amounts to good news for technology innovators, the Supreme Court ruled on behalf of CLS Bank in their suit brought against Alice Corporation. Stemming from a patent that had been granted in 1999 to protect a software program for financial trading, the case, and patent, revolved around using a computer program to manage the traditional escrow process.

Read more

How Employers Should Handle MLR Rebates

For the third year, employers who sponsor an insured group health plan may be receiving a Medical Loss Ratio (MLR) rebate from their insurers. Self-funded medical benefit plans are not subject to these requirements. The rebates raise several fundamental questions for employers including:

Read more

Final Rules – 90 Day Waiting Period & Orientation Period

Final regulations were released by the Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury (IRS) (The Departments) regarding the Affordable Care Act (ACA) 90-day waiting period rules, including the new, one month “orientation period”, which may be imposed prior to the start of the waiting period.  
Background

Read more

What the Supreme Court Hobby Lobby Case Means to Employers

In a 5 to 4 decision, the Supreme Court has ruled that certain privately held corporations do not have to comply with some of the Affordable Care Act’s (ACA) contraception coverage requirements if they violate the owner’s religious views. The decision opens the door for companies that meet the IRS definition of a “closely held corporation” to opt-out of providing certain contraception coverage in their employer sponsored group health plan.

Read more

Self-funded Employers and the HIPAA Health Plan Identifier Number (HPID)

The Department of Health and Human Services (HHS) has issued guidance regarding HIPAA electronic transactions related to the HIPAA privacy and security rules. According to the guidance, employers who sponsor self-funded health plans will be required to take certain administrative steps, including applying for a health plan identifier number (HPID) and getting certification from certain vendors that they are in compliance with HIPAA transaction rules.

Read more

Special Open Enrollment Offered to COBRA QBS and New ACA FAQs and COBRA Model Notices Released

New FAQs, released by the Department of Labor (DOL), Health and Human Services (HHS), and the Treasury (IRS), clarify certain requirements in regard to the annual out-of-pocket maximum, coverage for preventive services, health FSA carryover, and summary of benefits and coverage (SBC). Also, in states with the Federally-facilitated Marketplace, individuals currently on COBRA have been offered a special one-time open enrollment period.

Read more