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
On Friday, September 13, 2013 Treasury published Notice 2013-54 (Notice) which preserves all Health Flexible Spending Accounts (health FSAs) that are considered excepted benefits but eliminates an employer’s ability to use a stand-alone health FSA or other tax-favored arrangements, including Premium Reimbursement Arrangements or Health Reimbursement Arrangements (HRAs), 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 FSAs and HRAs. As such, this Alert is the second of two.
Health Savings Accounts are an integral component of the Consumer Directed HealthCare strategy. As HSAs gain mainstream acceptance in the marketplace it’s imperative that employers adopt an HSA solution that integrates with their core benefits offerings. Maintaining separation between the HSA and the underlying HDHP health plan will help avoid unnecessary disruption when the inevitable change of medical carrier occurs.
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.”
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!
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.
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.”
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.
Under health care reform, Patient Protection and Affordable Care Act (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 (HRAs) are categorized as self-insured health plans and are therefore subject to this fee unless, in rare occasions, it is determined to be an excepted benefit (i.e. for vision and dental expenses only).
The Patient Protection and Affordable Care Act includes many requirements applicable to employer group health plans. Some of these requirements are already effective but some of the most significant requirements will become effective in 2014. Employers should now be considering what they need to do to comply with ACA requirements that will become effective in 2014.
On April 30, 2013, the Internal Revenue (IRS) released proposed regulations which provide guidance on health care reform’s premium tax credit for the health insurance exchanges.
So employers and employees can take advantage of the health insurance Exchanges starting January 1, 2014, regulators issued some exceptions to the permitted election changes rule for cafeteria plans.
