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Getting a Grasp on the New Health-benefits Reporting Rules

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Category: ACA, Compliance and Regulatory,

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Getting a Grasp on the New Health-benefits Reporting Rules

BusinessWest on January 12, 2016 in Banking and Financial Services

Delayed Reaction

By BOB CUMMINGS

tl_files/content/about/Bios/RCummings_Head.jpgFor many employers, their first challenge with the Affordable Care Act (ACA) may be compliance with the new reporting requirements.

Under the ACA, the Internal Revenue Code added IRS Section 6056, which requires ‘applicable large employers’ to file information returns with the IRS and provide statements to their full-time employees about the health-insurance coverage that the employer offered. Under the terms of the ACA, an applicable large employer generally means an employer that had 50 or more full-time employees (including full-time equivalent employees) in the preceding calendar year.

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Getting a Grasp on the New Health-benefits Reporting Rules

(comments: 0)
Category: ACA, Compliance and Regulatory,

tl_files/content/blog/2016/BusinessWest.png

Getting a Grasp on the New Health-benefits Reporting Rules

BusinessWest on January 12, 2016 in Banking and Financial Services

Delayed Reaction

By BOB CUMMINGS

tl_files/content/about/Bios/RCummings_Head.jpgFor many employers, their first challenge with the Affordable Care Act (ACA) may be compliance with the new reporting requirements.

Under the ACA, the Internal Revenue Code added IRS Section 6056, which requires ‘applicable large employers’ to file information returns with the IRS and provide statements to their full-time employees about the health-insurance coverage that the employer offered. Under the terms of the ACA, an applicable large employer generally means an employer that had 50 or more full-time employees (including full-time equivalent employees) in the preceding calendar year.

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Group Health Plans that Fail to Cover In-Patient Hospitalization Services

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Category: ACA, Compliance and Regulatory, HHS,

Notice 2014-69

I.  PURPOSE AND OVERVIEW

The Department of Health and Human Services (HHS) and the Department of the Treasury (including the Internal Revenue Service) (collectively, the Departments) have become aware that certain group health plan benefit designs that do not provide coverage for in-patient hospitalization services are being promoted to employers.  A plan that fails to provide substantial coverage for these services would fail to offer fundamental benefits that are nearly universally covered, and historically have been considered integral to coverage, under typical employer-sponsored group health plans. Promoters of these plans contend that the plans satisfy minimum value within the meaning of the Affordable Care Act (including section 36B(c)(2)(C)(ii)of the Internal Revenue Code (Code) and final HHS regulations under section1302(d)(2)(C) of the Affordable Care Act (referred to in this notice as minimum value or MV)), as determined through use of the on-line MV Calculator referred to in final HHS regulations and proposed Treasury regulations.

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IRS Issues Notice Setting Adjusted Applicable Dollar Amount for PCOR Fee at $2.08

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Category: Compliance and Regulatory, Health Reimbursement Arrangements, HRA,

On Sept. 18, 2014, the IRS published Notice 2014-56, setting the applicable dollar amount for plan years that end on or after Oct. 1, 2014, and before Oct. 1, 2015. As a reminder, the PCOR fee is calculated using the average number of lives covered under the plan and the applicable dollar amount for that plan year. The applicable dollar amount is $2 for plan years ending after Oct. 1, 2013, and before Oct. 1, 2014. Notice 2014-56 announces that the applicable dollar amount for plan years that end on or after Oct. 1, 2014, and before Oct. 1, 2015, is $2.08. For plan years ending on or after Oct. 1, 2015, the adjusted applicable dollar amount will be published in future Internal Revenue Bulletin guidance.

With respect to payment responsibility, if a plan is fully insured, then the insurance carrier is responsible for paying the fee. If a plan is self-insured, the plan sponsor is responsible for the fee. For this purpose, “plan sponsor” is defined as the employer for a single employer plan.

IRS Notice 2014-56

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New Optional Section 125 Midyear Qualifying Events Released by IRS

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Category: Compliance and Regulatory, Flexible Spending, Section 125 Plans,

On Sept. 18, 2014, the IRS published Notice 2014-55, which creates two new Section 125 midyear qualifying events. The two new events apply in very specific situations and – like all Section 125 events – are optional. Employers who wish to include these new Section 125 qualifying events as options in their plan design need to amend the plan document accordingly.

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Compliance Update

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Category: Compliance and Regulatory, HCSO,

The San Francisco Board of Supervisors passed an amendment to the Health Care Security Ordinance on June 17,
2014. The amendment phases in (over 3 years) a requirement that all heath care expenditures be made irrevocably and makes other changes to the HCSO. For more information, see the HCSO amendment as passed.

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One-Time Special Enrollment for COBRA participants

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Category: COBRA, Compliance and Regulatory,

On May 2, 2014, the Centers for Medicare and Medicaid Services (part of HHS) issued a bulletin to deal with Special Enrollment Periods (SEPs).

HHS is concerned that former Model COBRA Continuation Coverage Election Notices (Model Election Notices) published by the Department of Labor and other documents provided by employers did not address, or did not sufficiently address, Marketplace options for persons eligible for COBRA.

The concern? Persons eligible for COBRA and their qualified beneficiaries may have had insufficient information to understand that they cannot voluntarily drop COBRA and enroll in the Marketplace outside of Marketplace open enrollment.

As a result, in accordance with 45 CFR 155.420(d)(9), HHS is providing an additional special enrollment period based on exceptional circumstances so that persons eligible for COBRA and COBRA beneficiaries are able to select Qualified Health Plans (QHPs) in the Federally Facilitated Marketplace (www.healthcare.gov).

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CMS Issues Guidance Related to COBRA Coverage and Exchange Eligibility

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Category: COBRA, Compliance and Regulatory,

On April 21, 2014, CMS issued guidance, in the form of a frequently asked question (FAQ), clarifying how COBRA coverage impacts an individual's eligibility to enroll in the exchange and to receive a premium tax credit. As background, the open enrollment period for almost all exchanges ended March 31, 2014. Individuals may only enroll in the exchange midyear if they qualify for a special enrollment period due to a qualifying event. The FAQ clarifies that during the open enrollment period for the exchange, an individual who has voluntarily terminated his/her COBRA coverage (i.e., COBRA coverage has not been exhausted) will be eligible to enroll in a qualified health plan through the exchange.

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Treasury Department Delays ACA Employer Mandate for Certain Employers

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Category: Compliance and Regulatory,

Treasury Department Delays Affordable Care Act (ACA) Employer Mandate Until 2016 for Employers with 50-99 Employees that Do Not Yet Provide Affordable Insurance to Full Time Workers

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Keeping Health Reimbursement Arrangements (HRAs) as a part of your benefit offerings

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Category: Compliance and Regulatory, Health Reimbursement Arrangements, HRA,

On Friday, September 13, 2013 Treasury published Notice 2013-54 (Notice) which preserves all Health Reimbursement Arrangements (HRAs) that are integrated with an underlying group health plan but eliminates an employer's ability to use a stand-alone or other tax-favored arrangements, including Premium Reimbursement Arrangements or cafeteria plans, to help employees pay for individual health policies on a tax-free basis. In addition, the Notice addresses a number of specific topics related to flexible spending accounts (FSAs) and HRAs. As such, this Alert is the first of two covering Notice 2013-54 which spells out requirements for HRAs offered starting January 1, 2014. Treasury and IRS Notice 2013-54

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Important Affordable Care Act Deadline: Employee Notices of the Health Insurance Marketplace (Exchange) Due by October 1, 2013 (copy)

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Category: CDHC, COBRA, Compliance and Regulatory, DOL, Health Care Reform, IRS, PPACA, Taxes,

On May 8, 2013, the Employee Benefits Security Administration of the U.S. Department of Labor (“DOL”) issued Technical Release No. 2013-02 (“Release”) providing important guidance under the Patient Protection and Affordable Care Act, as amended by the Health Care and Education Reconciliation Act of 2010 (“Affordable Care Act”), with regard to the requirement that employers provide notices to their employees of the existence of the Health Insurance Marketplace (“Marketplace”), previously referred to as the “Exchange.”

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What To Do Now? Re-forming What We Know About Health Care Reform

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Category: CDHC, Compliance and Regulatory, DOL, Health Care Reform, PPACA,

By Justyn Harkin, Communications Specialist, The Jellyvision Lab

Wow, did someone get the license number from that truck? My head is spinning. I mean, one moment I was just minding my own business, peacefully thinking about clever ways to explain coverage options to employees, and the next—major changes to key provisions of the ACA!

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ACA Employer Mandate is Delayed Until 2015

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Category: CDHC, Compliance and Regulatory, DOL, ERISA, Health Care Reform, HHS, PPACA, Taxes,

The Affordable Care Act (ACA) employer mandate provision has been delayed until 2015. This news was announced July 2, 2013 by the ​US Department of the Treasury on behalf of the Administration.

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Important Affordable Care Act Deadline: Employee Notices of the Health Insurance Marketplace (Exchange) Due by October 1, 2013

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Category: CDHC, COBRA, Compliance and Regulatory, DOL, Health Care Reform, IRS, PPACA, Taxes,

On May 8, 2013, the Employee Benefits Security Administration of the U.S. Department of Labor (“DOL”) issued Technical Release No. 2013-02 (“Release”) providing important guidance under the Patient Protection and Affordable Care Act, as amended by the Health Care and Education Reconciliation Act of 2010 (“Affordable Care Act”), with regard to the requirement that employers provide notices to their employees of the existence of the Health Insurance Marketplace (“Marketplace”), previously referred to as the “Exchange.”

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DOL Releases Model Notice and Guidance on PPACA’s Exchange Notice Requirement

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Category: Compliance and Regulatory, DOL, Health Care Reform, PPACA,

On May 8, 2013, the DOL issued Technical Release No. 2013-02, which includes temporary guidance and a model notice relating to the notice to employees of coverage option (known as the “Exchange Notice”) requirement under PPACA. As background, PPACA requires employers subject to the FLSA to provide each employee with a written notice that describes information about the state health insurance exchanges (also referred to as “marketplaces”), including the availability of premium tax credits and the implications relating to purchasing coverage through the exchanges.

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