United Benefit Advisors Insight and Analysis Blog

Karen Hsu

Recent Posts

IRS Releases Draft Forms and Instructions for 2018 ACA Reporting

Posted by: Karen Hsu    Sep 27, 2018 1:12:48 PM

The IRS recently released draft instructions for both the 1094-B and 1095-B and the 1094-C and 1095-C and the draft forms for 1094-B, 1095-B, 1094-C, and 1095-C. There are no substantive changes in the forms or instructions between 2017 and 2018, beyond the further removal of now-expired forms of transition relief. There is a minor formatting change to draft Form 1095-C for 2018. There are dividers for the entry of an individual’s first name, middle name, and last name.

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Topics: ACA Advisor, ACA reporting, health care coverage, compliance with health care reform, IRS reporting

DOL and IRS Release Additional Information on Association Health Plans

Posted by: Karen Hsu    Sep 20, 2018 1:04:47 PM

On August 20, 2018, the Department of Labor (DOL) posted the Association Health Plans ERISA Compliance Assistance fact sheet.

On August 20, 2018, the IRS added a new Q&A 18 to its Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care Act. Q&A 18 confirms that:

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Topics: Department of Labor, association health plans, Internal Revenue Service

Final Rule on Short-Term, Limited-Duration Insurance

Posted by: Karen Hsu    Sep 13, 2018 1:55:19 PM

On August 3, 2018, the Internal Revenue Service, the Department of Health and Human Services (HHS), and the Department of Labor (collectively, the Departments) published a final rule that amends the definition of short-term, limited-duration insurance. HHS also released a fact sheet on the final rule.

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Topics: health insurance, Department of Health and Human Services, Department of Labor, Internal Revenue Service

Final Rule on Short-Term Limited-Duration Insurance

Posted by: Karen Hsu    Aug 23, 2018 1:04:47 PM

On August 1, 2018, the Internal Revenue Service, the Department of Health and Human Services (HHS), and the Department of Labor (collectively, the Departments) released a final rule that amends the definition of short-term, limited-duration insurance. HHS also released a fact sheet on the final rule.

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Topics: health insurance, Department of Health and Human Services, short-term insurance

Cobra Liability in Mergers and Acquisitions

Posted by: Karen Hsu    Aug 9, 2018 3:58:41 PM

The Consolidated Omnibus Budget Reconciliation Act (COBRA) requires certain group health plans to make continuation coverage available to certain individuals who would otherwise lose group health plan coverage due to a qualifying event. Employers who go through business reorganizations, such as mergers and acquisitions (M&A), will need to know whether COBRA continuation coverage must be offered and whether the group health plan of the seller or buyer must provide COBRA continuation coverage.

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Topics: COBRA, Group health plans, group health insurance

Question of the Month

Posted by: Karen Hsu    Jul 26, 2018 12:52:33 PM

Q.For a high deductible health plan (HDHP) to qualify for health savings account (HSA) eligibility, what is the minimum amount that an embedded individual deductible can be?

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Topics: High Deductible Health Plans, HSA, health savings account, HDHPs

DOL Issues Final Regulations Regarding Association Health Plans

Posted by: Karen Hsu    Jul 19, 2018 1:22:12 PM

On June 19, 2018, the U.S. Department of Labor (DOL) published Frequently Asked Questions About Association Health Plans (AHPs) and issued a final rule that broadens the definition of “employer” and the provisions under which an employer group or association may be treated as an “employer” sponsor of a single multiple-employer employee welfare benefit plan and group health plan under Title I of the Employee Retirement Income Security Act (ERISA).

 

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Topics: association health plans, Department of Labor, DOL

Question of the Month: Penalties for failing to comply with Section 125 requirements

Posted by: Karen Hsu    Jul 12, 2018 12:55:32 PM

Q.What are the penalties for failing to comply with Section 125 requirements, such as failing to follow a cafeteria plan document’s terms?

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Topics: Section 125 plan, cafeteria plan, penalties

IRS Issues Transition Relief Notice for Plans with Male Sterilization or Contraceptive Benefits

Posted by: Karen Hsu    May 31, 2018 11:00:00 AM

Recently, some states adopted laws that
require certain health insurance policies to
provide benefits for male sterilization and male contraceptives without cost-sharing.

However, under health saving account (HSA) eligibility requirements, a high deductible health plan (HDHP) generally may not provide benefits for any year until the minimum deductible for that year is satisfied. Although an HDHP may provide preventive care without a deductible or with a deductible that is below the minimum annual amount required by HSA eligibility requirements, male sterilization and male contraceptives are not considered preventive care under the Social Security Act or any Treasury Department guidance.

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Topics: HDHPs, HSAs, IRS Notice 2018-12