Employers May Apply a Reasonable, Good Faith Interpretation of the Term ‘Seasonal Worker’ Employers looking to hire seasonal workers this summer are reminded that there is an exception when measuring workforce size to determine whether they are an applicable large employer (ALE) subject to the Affordable Care Act’s employer shared responsibility (“pay or play”) provisions.…
Affected Employers Must File IRS Form 720 Employers that sponsor certain self-insured health plans—including some health reimbursement arrangements (HRAs) and health flexible spending arrangements (health FSAs)—are reminded that they are responsible for Patient-Centered Outcomes Research Institute (PCORI) fees. Fees for self-insured plans with plan years that ended in 2017 are due July 31, 2018, and…
The IRS has released a Revenue Procedure, which increases the affordability threshold for ACA (“Affordable Care Act”) Employer Mandate Purposes (“Pay or Play”) to 9.86% for plan years beginning in 2019. For reference purposes: 2015 Percentage: 9.56% 2016 Percentage: 9.66% 2017 Percentage: 9.69% 2018 Percentage: 9.56% 2019 Percentage: 9.86% The Pay or Play rules only…
All group health plans that provide prescription drug coverage to Medicare Part D eligible individuals (whether actively working, retired, or disabled) are required to notify CMS whether or not the coverage provided is creditable. This disclosure must be filed with the Department of Health and Human Services within 60 days of the start of the…
On May 10, 2018, the IRS released Revenue Procedure 2018-30 to announce the inflation-adjusted limits for health savings accounts (HSAs) and high deductible health plans (HDHPs) for 2019. These limits include: The maximum HSA contribution limit; The minimum deductible amount for HDHPs; and The maximum out-of-pocket expense limit for HDHPs. These limits vary based on…
Group health plans and tax-favored accounts—including health savings accounts (HSAs), health flexible spending arrangements (health FSAs), and health reimbursement arrangements (HRAs)— are subject to numerous nondiscrimination provisions under federal law. As a result, employers that wish to adopt arrangements which exclude certain classes of employees from group health plan coverage or offer different benefits or…
On April 9, 2018, the Department of Health and Human Services (HHS) issued final regulations and related guidance on Affordable Care Act (ACA) provisions including Essential Health Benefits (EHBs), out-of-pocket (OOP) maximums, and Marketplace updates and reforms. These regulations, generally effective for plans and plan years beginning on and after Jan. 1, 2019, largely mirror…
The Internal Revenue Service (IRS) has re-established $6,900 as the 2018 health savings account (HSA) contribution limit for individuals with family coverage under a high deductible health plan (HDHP). This limit was previously announced as $6,900 in May 2017, but was revised to $6,850 in March 2018 due to an inflation adjustment provision in the…
A previously extended transitional policy that permits health insurance issuers to continue group coverage that would otherwise be terminated or cancelled due to the Affordable Care Act (ACA) has been further extended to policy years beginning on or before October 1, 2019, provided that all policies end by December 31, 2019. Health insurance issuers that…
New Rule Changes Disability Claim Processing Requirements Effective for disability benefit claims filed after April 1, 2018, a new rule from the U.S. Department of Labor (DOL) requires ERISA-covered employee benefit plans offering disability benefits to provide additional procedural protections to claimants. The new rule ensures that protections for disability claimants parallel protections under the…
