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Check it Out and Check it Off: 2015 Group Health Plan Checklist

October 14, 2014

Authors

benefitsbclp

Check it Out and Check it Off: 2015 Group Health Plan Checklist

October 14, 2014

by: benefitsbclp

460326385With 2015 just around the corner, certain mandates under the Patient Protection and Affordable Care Act, as amended (“ACA”) are about to become effective. Health plans also have several existing enrollment and annual notice requirements. Below is a checklist of upcoming ACA mandates that employers must implement in preparation for or in 2015 and a summary of existing enrollment and annual notice requirements.

For a refresher on the ACA mandates which became effective this year, please see our 2014 group health plan checklist here.

I. ACA Requirements That Apply to All Group Health Plans (Whether Grandfathered or Not)

On or beginning with the dates specified below, a group health plan must comply with the following requirements, regardless of its status as a “grandfathered health plan”:

Obtain a Health Plan Identifier Number (HPID).

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Reminder: PCORI Fee Due by 7/31

July 19, 2013

Authors

Chris Rylands

Reminder: PCORI Fee Due by 7/31

July 19, 2013

by: Chris Rylands

Don’t forget to prepare to report and pay your Patient-Centered Outcomes Research Institute fee! The first annual payment is due July 31, 2013. The fee is based on the number of participants in your plan during the prior year.

IRS Form 720, a Quarterly Federal Excise Tax Return, is used to report and pay the fee.  Here is a link to the instructions.

See also our prior posts relating to these fees.

Update 7/25/13: Also, the IRS has posted some FAQson the PCORI Fee as well

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Health Care Reform: Where are We Now that ACA’s Employer Mandate Has Been Delayed for One Year?

July 10, 2013

Authors

Lisa Van Fleet

Health Care Reform: Where are We Now that ACA’s Employer Mandate Has Been Delayed for One Year?

July 10, 2013

by: Lisa Van Fleet

The Benefits world was rocked last week when it was announced that enforcement of the ACA employer shared responsibility penalties would be delayed for one-year. IRS Notice 2013-45, released late yesterday, July 9, officially confirmed the delay, but provided no real additional guidance.  Employers are asking, what exactly this means?  Read on for our summary of where things stand.

I.     What ACA requirements are delayed in 2014?

  • Employer Mandate:  Employers must offer coverage to employees who work on average 30+ hours per week.
  • Affordability:  Coverage must be affordable (i.e., the employee’s share of the coverage cost cannot exceed 9.5% of the employee’s household income).
  • Minimum Value:  Coverage must provide minimum value (although this requirement is waived, employer must still report whether a plan provides minimum value on the SBC).
  • Certain Reporting Requirements:  Employers (and insurers) must provide information
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FAQs Part XI – Exchanges, Medicare Part D, Guns, and More!

January 29, 2013

Authors

Chris Rylands

FAQs Part XI – Exchanges, Medicare Part D, Guns, and More!

January 29, 2013

by: Chris Rylands

On January 24, the Departments overseeing health care reform implementation issued additional FAQs.  (Despite this being the 11th installment of FAQs, the Departments still has yet to address the most frequently asked question we receive from clients about the Affordable Care Act, which is, “Are you kidding me?”  A.: “No.”).

The Departments addressed the following issues in the FAQs:

  • Under health reform, employers were supposed to provide a notice of the availability of coverage through health insurance exchanges by March 1.  That deadline has been pushed back until after regulations can be issued.
  • The FAQs also talk about HRAs.  Essentially, unless the health reimbursement arrangement is truly and completely integrated with a group health plan (meaning the participant only gets the HRA if he or she is also enrolled in major medical coverage from the employer that complies with PPACA), it
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Patient-Centered Outcomes Research Trust Fund Fees (“PCORI” Fees) Final Regulations Issued

December 28, 2012

Authors

benefitsbclp

Patient-Centered Outcomes Research Trust Fund Fees (“PCORI” Fees) Final Regulations Issued

December 28, 2012

by: benefitsbclp

Recently, the Department of Treasury issued final regulations on the fees imposed to fund the Patient-Centered Outcomes Research Institute (“PCORI”), a private non-profit corporation that gathers research-based information to assist patients, practitioners and policy makers in making informed health care decisions.  (Our discussion of the proposed regulations is here.) The fees, to be paid by issuers of health insurance policies and sponsors of self-insured health plans, were instituted as part of the Patient Protection and Affordable Care Act (“PPACA” or “Health Care Reform”).  They apply to policy and plan years ending on or after October 1, 2012 and before October 1, 2019.

Although the fee applies to insured and self-insured plans, because the insurance issuer is responsible for paying the fee on insured plans, this post focuses on the fee as applied to self-insured employer-sponsored health plans.

How Much?

The PCORI fee is $2

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Considering Whether to Play or Pay: Taking Into Account PPACA’s New Research Fees

August 28, 2012

Authors

Serena Yee and Chris Rylands

Considering Whether to Play or Pay: Taking Into Account PPACA’s New Research Fees

August 28, 2012

by: Serena Yee and Chris Rylands

Now that the Patient Protection and Affordable Care Act, as amended by the Health Care and Education Reconciliation Act (“PPACA”) has been upheld by the U.S. Supreme Court, employers need to consider whether to “play or pay”.  Among the many factors an employer should consider in making its determination are (1) the transitional reinsurance fee (which we will discuss in an upcoming post) and (2) the new annual fee intended to fund clinical effectiveness research.

Employers with fully insured plans should note that even though responsibility for reporting and paying the annual fee rests with the health insurance issuers, such expense will likely be passed along by the issuer to policyholders in the form of increased premiums.

Covered Plans

Employers who sponsor one or more of the following health plans on a self-funded basis will be subject to the annual fee based on the average number

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IRS Releases Proposed Rules on New Comparative Effectiveness Fee for Health Plans

April 16, 2012

Authors

benefitsbclp

IRS Releases Proposed Rules on New Comparative Effectiveness Fee for Health Plans

April 16, 2012

by: benefitsbclp

On April 12, the IRS released proposed regulations regarding the collection of the fee for the Patient-Centered Outcomes Research Trust Fund (the “Fund”) under the Patient Protection and Affordable Care Act (“PPACA”). The Fund will be used to pay for the Patient-Centered Outcomes Research Institute which has the goal of helping health care providers and consumers make informed health decision by synthesizing research comparing the outcome effectiveness of various treatments.

Who Pays for This

Here’s the kicker: insurers and self-insured health plans get to pay for this, along with multiemployer plans, state and local governmental plans, stand-alone VEBAs and other health plans. We focus primarily on private employer plans, but many of the rules apply similarly to other types of plans.

How Much

Initially, the fee is $1 per covered life. It will first apply for plan or policy years ending between October 1, 2012 and October 1,

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