PPACA FAQs & Implementation Part 11

PPACA FAQs & Implementation Part 11

If you’ve been following along with our PPACA-timelines you’ve seen on the 2013 Timeline the blurb that Employer/Plan Sponsors are required to “Provide employees with HHS information notices about 2014 exchanges and subsidies.”  You may also recall that this was supposed to be accomplished by March 1st  of this year.

Well, the DOL is not ready to put these notices together and they wish to coordinate efforts with Health and Human Services (HHS) and the Treasury Department (IRS).  (See Question/Answer number 1).  Accordingly, they have moved that deadline back to this summer.

The DOL’s FAQs also offer some guidance on these topics:

  • Questions 2, 3 and 4 deal with HRAs:   Can an HRA be used to purchase coverage on the individual market and satisfy the PPACA mandate that employers offer coverage?  Can an employer offer an “integrated HRA” and let employees take the HRA without taking the medical plan?   How will unused HRA amounts credited before 1/1/2014 be applied?
  • Question 5 asks whether the Public Health Service Act restricts communications between health care professionals and their patients concerning firearms and ammunition.
  • Question 6 offers limited guidance for self-funded drug plans that offer retiree coverage and Medicare D supplements.
  • Question 7 deals with fixed indemnity coverage and when they are “excepted benefits”.
  • Finally the FAQs round out their guidance on the topic of the PCORI fees (the Patient Centered Outcomes Research Institute) the $1 times the average number of covered lives fee, which jumps to $2 in the 2nd year and remains at $2 until it sunsets after 2019’s payments.  See timeline, 2013 (entry “d”) and 2020.