Articles
Cadillac Tax – 2015 IRS Notices
Thursday, September 17, 2015
The Internal Revenue Service (IRS) has released two separate notices this year requesting comments on how to administer the excise tax on high-cost health coverage (also known as the “Cadillac tax”) set to go into effect for the 2018 tax year.
Medicare Part D Notice Reminder
Tuesday, September 15, 2015
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.
Employer Reporting – HRA Reporting Requirement
Thursday, September 3, 2015
In the recent draft instructions released by the IRS in regards to employer reporting on Forms 1094 and 1095, the IRS indicates that reporting is required for health reimbursement accounts (HRAs) integrated with fully-insured plans.
SDI Gains Marketshare in the Northwest
Monday, August 17, 2015
Subcontractor Default Insurance (SDI) has become a much more visible feature on major construction projects in the Northwest. Our region was arguably the last to embrace SDI.
Washington State’s Data Breach Notification Law Changes (House Bill 1078) and Data Breach Fiduciary Responsibilities for Healthcare Organizations
Wednesday, July 29, 2015
Effective July 24th, 2015, Washington State law H.B. 1078 amends the State’s data breach notification statue. The amendment:
– Expands the statute to cover breaches of non-computerized data (hard copy data – which almost every business still houses)
– Imposes a 45-day deadline for notification of affected consumers (as opposed to 60 days previously)
– Mandates the notification of Washington State Attorney General for breaches larger than 500 Washington state residents
– Introduces a safe harbor for personal information that is secured or encrypted in a manner that meets or exceeds the National Institute of Standards and Technology (NIST) requirements
Small Group Market – Changing Definition
Thursday, July 16, 2015
Beginning in 2016, the definition of “small employer” for insurance rating and underwriting purposes changes. In general, employers with 51–100 full-time equivalents (FTEs) may now fall into the small employer category, and such groups will be subject to community rating and be required to offer essential health benefits for the first time. However, transition relief issued by the Department of Health & Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) allows states and insurers to choose to renew current policies through October 1, 2016. In other words, depending upon which state the insurance policy is being issued out of, employers with 51–100 FTEs, may have the option to renew their current policies through October 1, 2016. As of July 15, neither Alaska nor Washington states have announced any intention of adopting this transitional relief.
Supreme Court Rules on Same-Sex Marriage and Employee Benefits
Thursday, July 9, 2015
Last week the U.S. Supreme Court ruled in Obergefell v. Hodges that all states must permit same-sex marriages within their borders and must recognize same-sex marriages performed in other states. This ruling puts to rest some of the big questions and the confusion that remained after the Court’s ruling on same-sex marriage and DOMA in 2013. Many employers must now consider how this decision affects their benefit plans.
Affordability Consideration
Monday, June 29, 2015
It is important to understand whether coverage offered under an employer-sponsored group health plan is “affordable” for compliance with the employer shared responsibility rules under Section 4980H and for purposes of individual eligibility for tax subsidies through a public exchange. When setting plan contribution rates, employers should consider the IRS employer affordability safe harbors, the […]
Supreme Court Rules Subsidies Are Available Through the Federal Marketplace (Exchange)
Thursday, June 25, 2015
In a 6-3 decision, the Supreme Court has ruled that Affordable Care Act (ACA) subsidies will continue to be available to certain individuals who purchase health insurance plans in states that use the Federal Marketplace. This decision is important for employers as they work to implement the strategies necessary to comply with ACA employer requirements.
PCORI Fees Due July 31
Monday, June 22, 2015
Employers who sponsor self-funded medical plans must report and pay the ACA Patient-Centered Outcomes Research Institute (PCORI) fees no later than July 31, 2015. Health insurance carriers/insurers will pay the fee directly in the case of fully-insured plans.
Employer Reporting Requirements
Monday, May 18, 2015
Beginning in early 2016, employer reporting will be required for the first time based on data from the 2015 calendar year.
EEOC issues regulations addressing ADA requirements for employer wellness programs
Wednesday, April 29, 2015
The Equal Employment Opportunity Commission (EEOC) has issued long awaited proposed regulations on how employers can structure their wellness programs in relation to the American with Disabilities Act (ADA).
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