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Congress Passes “Cures Act” Allowing Stand-Alone HRAs for Small Employers

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

On Dec. 7, 2016, the US Congress passed HR 34, called the “21st Century Cures Act” (Cures Act). The Cures Act legislation will permit small employers (those with fewer than 50 full-time employees during a calendar year who are not subject to the employer mandate) who do not offer a group health plan to provide a qualified small employer health reimbursement arrangement (QSEHRA).

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American Benefits Group is Featured in the current edition of BusinessWest

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Category: CDHC, COBRA, Flexible Spending, FSA, Health Reimbursement, Health Reimbursement Arrangements, Health Savings, HRA, HSA, Section 125 Plans, Transit and Parking Section 132,

When Bob Cummings started out in benefits administration, health-insurance co-pays were $3, premiums were well under $100 a month, his office ran on MS-DOS, and it issued paper statements. Much has changed since then, obviously, but not his company’s success formula, based on personalization, creativity, knowledge of a complex and ever-changing subject, and what American Benefits Group prefers to call ‘enabling technology.’
 
George O'Brien on October 5, 2015 in BusinessWest


See the entire American Benefits Group story in the October 5th Issue of BusinessWest and BusinessWest.com 
http://businesswest.com/blog/abg-thrives-in-complex-world-of-benefits-administration/ 

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ACA Reporting and HRAs

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Category: ACA, Health Reimbursement Arrangements, HRA, IRS,

Section 6056 Update

Good news!  The IRS has changed their position on both of these issues!
 
We just received final 2015 versions of the instructions for Forms 1094-B, 1095-B, 1094-C, and 1095-C.
 
Reporting HRA Coverage
In the instructions for Forms 1094-B and 1095-B, the IRS states:

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IRS Issues FAQs relating to PPACA Informational Reporting under Sections 6055 and 6056

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Category: Health Reimbursement Arrangements, PPACA,

On Sept. 22, 2014, the IRS released two sets of FAQs discussing the informational reporting requirements under Internal Revenue Code Sections 6055 and 6056. Section 6055 requires employers that sponsor self-insured plans to report specific information to the IRS and to plan participants which will assist the IRS in administering and enforcing the individual mandate. 

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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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Patient Centered Outcomes Research Institute (PCOR)

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Category: Health Reimbursement Arrangements, HRA, PCOR, PPACA,

Under health care reform (PPACA), a new nonprofit corporation was established, the Patient Centered Outcomes Research Institute (PCOR).  This corporation will be funded in part by PCOR/CER (comparative effectiveness research) fees paid by certain health insurance issuers or plan sponsors of applicable self-insured health plans.  Please note that Health reimbursement Arrangements (HRA) are categorized as a self-insured health plans unless, in rare occasions, it is determined to be an excepted benefit (i.e. for vision and dental expenses only) and are therefore subject to this fee.

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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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