The Health Care Reform Act created the transitional reinsurance program, which requires most self-insured health plans to make contributions to HHS for the 2014, 2015, and 2016 calendar years. The contribution amount is determined by the number of covered lives under each plan. The number of covered lives must be calculated and submitted to HHS […]
NW
On September 18, 2014, the IRS released IRS Notice 2014-55, which now allows employees to make certain mid-year health coverage changes when they reduce below 30 hours of service or enroll in a qualified health plan through a Marketplace. Employers who want to permit either of these two new changes (which are explained in detail […]
NC
On January 17, 2013, the U.S. Department of Health and Human Services (HHS) issued a final rule under HIPAA making substantial changes to the rules for vendors that provide services to HIPAA-covered plans, such as third-party administrators, pharmacy benefit managers and certain brokers – known in the HIPAA world as “Business Associates.” Under this final […]
MS
Nancy Campbell recently wrote a newsletter that discussed how health care reform impacts COBRA. One of the issues that Nancy addressed is subsidized COBRA and severance arrangements. The purpose of this blog is to dive deeper into the issues employers should consider when providing subsidized post-termination COBRA benefits. • Providing Post-Termination Medical Benefits on an After-Tax […]
GG
In our 2013 End of Year Plan Sponsor “To Do” List Part 2 – Health and Welfare I did a lengthy summary of the various changes required to employer health care arrangements on account of IRS Notice 2013-54. On May 6, 2014, I followed that up with a blog entitled Non-integrated health reimbursement arrangements (whatever […]
NC
A summary plan description, or SPD, is the document that is given to participants and beneficiaries explaining the material terms of an ERISA plan. Both pension plans and welfare plans are required to provide SPDs to participants. An SPD generally must be provided when a participant first becomes covered by a plan. It also must […]
AM
Plan administrators that fail to timely file their Form 5500s can be subject to penalties under both ERISA and the Code. The Department of Labor’s Delinquent Filer Voluntary Compliance Program (“DFVCP”) provides plan administrators with the opportunity to pay reduced Department of Labor penalties for late Form 5500 filings. The DFVCP among other things, requires […]
GG
I gave a presentation last week at the Western Pension & Benefits Conference Phoenix Chapter Spring Conference entitled “Ding Dong DOMA’s Dead – The Supreme Court’s Same-Sex Marriage Ruling and Its Impact on Employee Benefit Plans.” Upon finishing my presentation, I realized my last few slides are a good checklist. On April 4th, the IRS […]
NC
Earlier this year, I blogged about how the IRS modified the health flexible spending account (“health FSA”) “use-it-or-lose-it” rule to allow carryovers of up to $500 to subsequent plan years. This rule change caused some confusion. Employers were asking, “what happens to an employee’s eligibility to contribute to a health savings account (“HSA”) if they […]
KH
As explained in my Checklist for Employers, a large employer will have to pay a subsection (a) penalty for any month if it does not offer “minimum essential coverage” (“MEC”) to substantially all (i.e., 70% for 2015 and 95% for future years) of its full-time employees and their dependents if one or more full-time employees […]
NC
