Creditable Coverage Notice and Disclosure (Employer Medicare Part D Notice Due Oct. 15)
October 9, 2018
Employers offering group health coverage that includes any prescription drug benefits must complete two notice and disclosure requirements at this time each year:
1. Provide a written notice to all Medicare-eligible plan participants before each October 15 explaining whether the plan’s prescription drug coverage is “creditable coverage” (i.e., the coverage is expected to pay on average as much as Medicare’s standard prescription drug coverage).
2. Complete the Online Disclosure to CMS Form within the first 60 days of each plan year disclosing whether the plan’s prescription drug coverage is “creditable coverage.” CMS is the Centers for Medicare and Medicaid Services, a federal agency that collects data and administers various federal programs. Continue reading.
IRS Issues Affordability Percentage Adjustment For 2019
June 7, 2018
In Rev. Proc. 2018-34, the IRS released the inflation adjusted amounts for 2019 relevant to determining whether employer-sponsored coverage is “affordable” for purposes of the Affordable Care Act’s (ACA’s) employer shared responsibility provisions and premium tax credit program. For plan years beginning in 2019, the affordability percentage is 9.86% of an employee’s household income or applicable safe harbor. Continue reading.
Webinar: 2018 Compliance UpdateJune 5, 2018
On June 5, Stacy Barrow of Marathas Barrow Weatherhead Lent LLP walked us through the Health & Welfare Benefit Plan Compliance Checklist for 2018 and provided instructions related to basic rules and responsibilities for benefit plan sponsors. View the webinar here.
Reminder PCORI Fees Due By July 31, 2018
May 14, 2018
Employers that sponsor self-insured group health plans, including health reimbursement arrangements (HRAs) should keep in mind the upcoming July 31, 2018 deadline for paying fees that fund the Patient-Centered Outcomes Research Institute (PCORI). The IRS has recently released Form 720 for second quarter 2018, which is used to remit the fee. Note that the PCORI fee does not apply to most health FSAs. Continue reading.
IRS Adjusts HSA Contribution Limit...Again
April 27, 2018
The IRS has announced it is modifying the annual limitation on deductions for contributions to a health savings account (HSA) allowed for taxpayers with family coverage under a high deductible health plan (HDHP) for the 2018 calendar year. Under Rev. Proc. 2018-27, taxpayers will be allowed to treat $6,900 as the annual limitation, rather than the $6,850 limitation announced in Rev. Proc. 2018-18 earlier this year. Continue reading.
The Equal Employment Opportunity Commission (EEOC) Status Report in AARP v. EEOC Creates Uncertainty for Wellness Programs
April 16, 2018
In its March 30 status report to the U.S. District Court for the District of Columbia in American Association for Retired Persons (AARP) v. EEOC, the U.S. Equal Employment Opportunity Commission (EEOC) stated that “it does not currently have plans to issue a Notice of Proposed Rulemaking addressing incentives for participation in employee wellness programs by a particular date certain, but it also has not ruled out the possibility that it may issue such a Notice in the future.” Continue reading.
IRS Adjusts Health Savings Account Contribution Limit, Provides Transition Relief for Certain Non-Compliant High Deductible Health Plans
March 7, 2018
In Rev. Proc. 2018-18, the Internal Revenue Service (IRS) has released adjusted contribution limits for health savings accounts (HSAs) due to changes made by the Tax Cuts and Jobs Act (TCJA). The new HSA contribution limit for individuals with family high deductible health plan (HDHP) coverage is $6,850, a $50 reduction from the previously announced inflation-adjusted amount for 2018. Other HSA/HDHP figures remain unchanged. Continue reading.
Short-Term Spending Bill Delays Cadillac Tax, Other ACA Taxes
January 24, 2018
On January 22, 2018, President Trump signed H.R. 195: Extension of Continuing Appropriations Act, 2018, which is a short-term spending bill that re-opened the federal government after a three-day shut-down. Continue reading.
Department of Labor Releases Proposed Rule Expanding Association Health Plans
January 23, 2018
Earlier this month, the U.S. Department of Labor issued a proposed rule to expand the opportunity of unrelated employers of all sizes (but particularly small employers) to offer employment-based health insurance through Association Health Plans (AHPs). Continue reading.
Department of Labor Announces April 1 Applicability of Final Disability Plan Claims Procedure Regulations
January 22, 2018
The U.S. Department of Labor announced its decision for April 1, 2018, as the applicability date for ERISA-covered employee benefit plans to comply with a final rule (released in December 2016) that imposes additional procedural protections (similar to those that apply to health plans) when dealing with claims for disability benefits. Continue reading.