
Articles
Self-funded Employers Must Report Membership by Nov. 17th for Purposes of Making ACA Reinsurance Payments
Wednesday, October 15, 2014
Employers who sponsor self-funded health plans must report their average membership numbers to the Department of Health and Human Services (HHS) no later than Nov. 17th. The reported membership will be used to calculate the amount due for 2014 contributions to the transitional reinsurance program. Employers will also need to schedule the first payment at the time the membership is reported. The first reinsurance contribution payment must be made no later than January 15, 2015.
Time is Running Short for Large Self-funded Employers to Obtain a HIPAA HPID Number
Friday, October 10, 2014
Time is running short for large self-funded employers to acquire a Health Plan ID Number (HPID) as required by HIPAA and the ACA. Employers who sponsor large health plans must obtain at least one Health Plan ID Number (HPID) by November 5th, 2014.
Final Rules Amending Definition of Excepted Benefits
Wednesday, October 8, 2014
The Departments of the Treasury, Labor, and HHS (the Departments) have released final rules that amend regulations regarding the definition of “ excepted benefits”.
Procuring Developer-Oriented Surety Bonds
Tuesday, October 7, 2014
At a recent construction industry event, a developer asked me why surety bonds have become so much harder for him to procure than in the past. The bonds he was referring to are bonds for things such as erosion control, storm water & drainage, grading & clearing, wetlands mitigation, landscaping and right of way, among others. He knew that reputation, work history and financial position all influenced qualification for surety bonds. But beyond qualifying one’s character, capacity and capital – three key components used in the surety qualification process – perhaps the biggest X factor is the number of surety markets willing to entertain developer-oriented surety.
PCORI Fee Increase
Monday, September 29, 2014
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.
Section 125 Rules to Recognize Two New Permitted Election Changes
Wednesday, September 24, 2014
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).
Medicare Part D Notice Reminder: Deadline of October 14th
Tuesday, September 16, 2014
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.
IRS Releases ACA Employer Reporting Instructions
Monday, September 8, 2014
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
Supreme Court Supports Innovation
Friday, August 1, 2014
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.
How Employers Should Handle MLR Rebates
Thursday, July 31, 2014
For the third year, employers who sponsor an insured group health plan may be receiving a Medical Loss Ratio (MLR) rebate from their insurers.
PCORI Fees due July 31
Wednesday, July 16, 2014
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, 2014. Health insurance carriers/insurers will pay the fee directly in the case of fully-insured plans.
Final Rules – 90 Day Waiting Period & Orientation Period
Wednesday, July 9, 2014
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.
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