Patrick C. Haynes, Jr., Esq., LL.M. The Department of Labor (DOL) issued additional guidance on May 11, 2012. Clarifying some points, federal regulators made clear(er), that they will not be imposing financial penalties on employers that do not “fully comply” with the Affordable Care Act’s new requirements to distribute SBCs (Summaries of Benefits and Coverage), […]
Read More...Update, 6/28/2012, 10:38 a.m. (EDT): 1 The Affordable Care Act (PPACA), including its individual mandate that virtually all Americans buy health insurance, is constitutional. 2 There were not five votes to uphold it on the ground that Congress could use its power to regulate commerce between the states to require everyone to buy health […]
Read More...Yesterday the IRS provided some relief for non 1/1 HCFSA plans. Under current law there is no dollar-limit-cap on HCFSAs. However, since HCFSAs contain a “uniform coverage provision”, meaning that the entire annual election is made available on the first day of the plan year, employers self-regulate their HCFSAs caps. Employers that are worried about […]
Read More...Key Dates for Self-Funded Plans to Keep in Mind 07-15-2012 Comments due to the IRS 08-08-2012 Public Hearing 10-01-2012 $1 per life fee assessed for plan years ending on/after 10-01-2012. 07-31-2013 Date upon which a 1/1 Plan must file an IRS Form 720 and pay fee The Affordable Care Act (PPACA) includes a provision imposing an […]
Read More...While the final rule on the SBCs makes several, important improvements over the preliminary rule (which you read about here on 9/16/2011, and then read about the delay on 11/18/11) employers and plan sponsors will still need to use the additional time to wrestle with potential costs and resources required to deliver something that will […]
Read More...On December 2, 2011, HHS and CMS (the Departments of Health and Human Services and the Centers for Medicare & Medicaid Services) released new final rules that addresses an assortment of issues with respect to the PPACA medical loss ratio (MLR) requirements. In conjunction with the new rules, the DOL (Department of Labor) has issued […]
Read More...With the release of Notice 2012-9, the Internal Revenue Service (IRS) has given more advice about how employers, benefit plan administrators and others should go about applying the new Form W-2 health benefits cost reporting requirements that were mandated by PPACA. This latest guidance (23 pages) updates, expands and replaces prior IRS Notices 2010-69 and […]
Read More...Essential Health Benefits (“EHB”) is a set of health care service categories that must be covered by certain plans, starting in 2014*. Starting with plan years or policy years that began on or after September 23, 2010, health plans can no longer impose a lifetime dollar limit on spending for these services. All plans, except […]
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