United Benefit Advisors Insight and Analysis Blog

CMS Allows States to Extend Life of "Grandmothered" or Transitional Health Insurance Policies

Posted by: Danielle Capilla    Mar 21, 2017 9:30:00 AM

On February 23, 2017, the Department of Health and Human Services' Centers for Medicare & Medicaid Services (CMS) released its Insurance Standards Bulletin Series, in which it re-extended its transitional policy for non-grandfathered coverage in the small group and individual health insurance markets.

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Topics: ACA, health plan benchmarking, UBA Health Plan Survey, Danielle Capilla, Affordable Care Act, grandmothering, transitional relief, transitional health insurance policy

Tax Treatment of Fixed Indemnity Health Plans

Posted by: Danielle Capilla    Mar 9, 2017 9:30:00 AM

A fixed indemnity health plan pays a specific amount of cash for certain health-related events (for example, $40 per office visit or $100 per hospital day). The amount paid is neither related to the medical expense incurred, nor coordinated with other health coverage. Further, a fixed indemnity health plan is considered an "excepted benefit."

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Topics: ACA, HIPAA, excepted benefits, Danielle Capilla, Affordable Care Act, fixed indemnity health plan, fixed dollar indemnity plans, taxation of health benefits

Medicare Part D: Creditable Coverage Disclosures

Posted by: Danielle Capilla    Mar 7, 2017 9:30:00 AM

Entities such as employers with group health plans that provide prescription drug coverage to individuals that are eligible for Medicare Part D have two major disclosure requirements that they must meet at least annually:

  • Provide annual written notice to all Medicare eligible individuals (employees, spouses, dependents, retirees, COBRA participants, etc.) who are covered under the prescription drug plan.
  • Disclose to the Centers for Medicare and Medicaid Services (CMS) whether the coverage is "creditable prescription drug coverage."
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Topics: Medicare Part D, Danielle Capilla, health care cost, annual disclosures, prescription drug coverage, creditable coverage notice

The “Line 22” Question: Which Box(es) Do I Check?

Posted by: Danielle Capilla    Mar 1, 2017 9:30:00 AM

Under the Patient Protection and Affordable Care Act (ACA), individuals are required to have health insurance while applicable large employers (ALEs) are required to offer health benefits to their full-time employees.

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Topics: ACA, employer shared responsibility, Danielle Capilla, Affordable Care Act, play or pay requirements, applicable large employers, IRS Form 1094-C

IRS Q&A About Employer Information Reporting on Form 1094-C and Form 1095-C

Posted by: Danielle Capilla    Feb 22, 2017 9:30:00 AM

The Internal Revenue Service (IRS) recently updated its longstanding Questions and Answers about Information Reporting by Employers on Form 1094-C and Form 1095-C that provides information on:

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Topics: ACA, Danielle Capilla, Affordable Care Act, COBRA continuation coverage, Form 1094-C, IRS reporting, Form 1095-C, offer of coverage

FAQ on HIPAA Special Enrollment; QSE HRAs Released

Posted by: Danielle Capilla    Feb 8, 2017 9:53:35 AM

Recently, the Department of Labor (DOL), Department of Health and Human Services (HHS), and the Treasury (collectively, the Departments) issued FAQs About Affordable Care Act Implementation Part 35. The FAQ covers a new HIPAA special enrollment period, an update on women's preventive services that must be covered, and clarifying information on qualifying small employer health reimbursement arrangements (QSE HRAs).

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Topics: HIPAA, group health insurance, health reimbursement arrangements, HRA, Danielle Capilla, 21st Century Cures Act, Qualified Small Employer HRA, benefits enrollment, women's preventive services

Cafeteria Plans: Qualifying Events and Changing Employee Elections

Posted by: Danielle Capilla    Feb 7, 2017 9:30:00 AM

Cafeteria plans, or plans governed by IRS Code Section 125, allow employers to help employees pay for expenses such as health insurance with pre-tax dollars. Employees are given a choice between a taxable benefit (cash) and two or more specified pre-tax qualified benefits, for example, health insurance. Employees are given the opportunity to select the benefits they want, just like an individual standing in the cafeteria line at lunch.

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Topics: ERISA, group health insurance, Danielle Capilla, change in status event, cafeteria plan, Section 125 plan, pre-tax benefits, taxable benefits

2017 Annual Limits Card Back by Popular Demand

Posted by: Danielle Capilla    Jan 18, 2017 9:30:00 AM

Many employee benefit limits are automatically adjusted each year for inflation (this is often referred to as an "indexed" limit). UBA offers a quick reference chart showing the 2017 cost of living adjustments for health and Section 125 plans, qualified plans, Social Security/Medicare withholding, compensation amounts and more. This at-a-glance resource is a valuable desk tool for employers and HR practitioners.

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Topics: health care costs, employee benefits, employee benefit limits, out-of-pocket limits, Danielle Capilla, group benefit plans

Interim Final Regulation on Maximum Civil Monetary Penalties

Posted by: Danielle Capilla    Dec 29, 2016 10:30:00 AM

The Department of Health and Human Services (HHS) recently issued interim final regulations that adjust for inflation the maximum civil monetary penalties (CMP) that fall under HHS's jurisdiction. The regulations reflect changes required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (the Act).

Adjustments under the Act were effective on August 1, 2016, and HHS's CMP adjustment regulations were effective on September 6, 2016. HHS issued its regulations for immediate implementation, without the notice and comment procedures that normally accompany new regulations.

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Topics: compliance, ACA, HIPAA, group health insurance, Danielle Capilla, Affordable Care Act, monetary penalties

Regulations Regarding Short-Term Limited-Duration Insurance, Excepted Benefits, and Lifetime/Annual Limits

Posted by: Danielle Capilla    Dec 27, 2016 10:30:00 AM

Recently, the U.S. Department of the Treasury, Department of Labor (DOL), and Department of Health and Human Services (HHS) (collectively the Departments) issued final regulations regarding the definition of short-term, limited-duration insurance, standards for travel insurance and supplemental health insurance coverage to be considered excepted benefits, and an amendment relating to the prohibition on lifetime and annual dollar limits.

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Topics: group health insurance, excepted benefits, supplemental health coverage, Danielle Capilla, travel insurance, short-term insurance