How Summer Hires May Impact ALE Status

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.…

Employers: Don’t Forget to Pay PCORI Fees

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…

IRS Releases 2019 ACA Affordability Threshold

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…

Creditable Coverage Disclosure Reminder

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…

IRS Announces HSA Limits for 2019

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…

Non Discrimination & Classing Rules for Health Plans: An Employer’s Guide

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…