United Benefit Advisors Insight and Analysis Blog

HHS Releases Inflation-Adjusted Federal Civil Penalty Amounts

Posted by: Karen Hsu    Jan 23, 2020 12:45:00 PM

The Department of Health and Human Services (HHS) issued its Annual Civil Monetary Penalties Inflation Adjustment. Here are some of the adjustments:

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Topics: HHS, HIPAA, Medicare, compliance recap

CMS Releases SBC Materials for Plan Years Beginning 2021

Posted by: Karen Hsu    Jan 16, 2020 7:46:00 AM

The Centers for Medicare and Medicaid Services (CMS) released SBC materials and supporting documents including a template SBC, sample completed SBC, uniform glossary, instructions, and guidance for plan or policy years beginning on or after January 1, 2021. 

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Topics: Medicaid, SBC, CMS, Medicare coverage, compliance recap

OCR and ONC Release HHS Security Risk Assessment Tool Version 3.1

Posted by: Karen Hsu    Dec 19, 2019 8:47:00 AM

The Office for Civil Rights (OCR) and the Office of the National Coordinator for Health Information Technology (ONC) have released version 3.1 of the HHS Security Risk Assessment (SRA) Tool.

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Topics: compliance recap, ONC, SRA

The Treasury Releases 2019-2020 Priority Guidance Plan

Posted by: Karen Hsu    Dec 5, 2019 8:35:00 AM

The Treasury released its 2019-2020 Priority Guidance Plan (Priority Guidance Plan) that sets forth guidance priorities for the Treasury and the Internal Revenue Service (IRS) during the twelve-month period from July 1, 2019, through June 30, 2020.

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Topics: FMLA, benefits, compliance recap, HFSAs, Priority Guidance Plan, FY2020

District Court Vacates Parts of ACA Section 1557 Nondiscrimination Rule

Posted by: Karen Hsu    Nov 21, 2019 8:29:00 AM

As background, the Patient Protection and Affordable Care Act (ACA) Section 1557 provides that individuals shall not be excluded from participation in, denied the benefits of, or be subjected to discrimination under any health program or activity which receives federal financial assistance from the Department of Health and Human Services (HHS), on the basis of race, color, national origin, sex, age, or disability. The current rule applies to any program administered by HHS or any health program or activity administered by an entity established under Title I of the ACA. These applicable entities are “covered entities” and include a broad array of providers, employers, and facilities. On May 13, 2016, the Department of Health and Human Services (HHS) issued a final rule (current rule) implementing Section 1557, which took effect on July 18, 2016.

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Topics: ACA, HHS, ACA Section 1557, compliance recap

DOL, HHS, and Treasury Release Final FAQs on Mental Health / Substance Use Disorder Parity

Posted by: Karen Hsu    Nov 14, 2019 9:30:00 AM

The U.S. Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury (collectively, the “Departments”) released final FAQs About Mental Health and Substance Use Disorder Parity Implementation and the 21st Century Cures Act Part 39. The Departments respond to FAQs as part of implementing the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA), as amended by the Patient Protection and Affordable Care Act (ACA) and the 21st Century Cures Act (Cures Act). The FAQs contain a model disclosure form that employees can use to request information from their group health plan or individual market plan regarding treatment limitations that may affect access to mental health or substance use disorder (MH/SUD) benefits.

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Topics: ACA, HHS, DOL, mental health, compliance recap, MHPAEA

IRS Releases Information Letter on Employer Shared Responsibility Penalties under the ACA

Posted by: Karen Hsu    Nov 7, 2019 9:45:00 AM

The Internal Revenue Services (IRS) released an information letter responding to an inquiry of whether employer shared responsibility penalties (ESRPs) may be waived or reduced based on hardship or other factors and whether the IRS will extend the transition relief for employers with fewer than 100 employees.

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Topics: ACA, IRS, compliance recap, ESRPs

IRS Announces Health Insurance Providers Fee to Resume in 2020

Posted by: Karen Hsu    Oct 29, 2019 9:12:00 AM

As background, the Patient Protection and Affordable Care Act (ACA) imposes a fee on each covered entity (for example, health insurers or a non-fully insured MEWA) engaged in the business of providing health insurance for United States health risks.

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Topics: ACA, IRS, ACA fees, compliance recap

IRS Publishes Proposed Rules on Affordability Safe Harbors and Nondiscrimination for ICHRAs

Posted by: Karen Hsu    Oct 22, 2019 8:32:00 AM

The Internal Revenue Service (IRS) published proposed rules clarifying how the employer shared responsibility provisions and Section 105(h) nondiscrimination rules apply to health reimbursement arrangements (HRAs) and other account-based group health plans that are integrated with individual health insurance coverage or Medicare.

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Topics: HRAs, IRS, compliance recap, Individual Coverage

DOL Issues Updated Medicaid / CHIP Model Notice

Posted by: Karen Hsu    Oct 10, 2019 10:36:48 AM

The Department of Labor (DOL) issued an updated Premium Assistance Under Medicaid and the Children’s Health Insurance Program (CHIP) Model Notice. Employers should distribute the updated model notice before the start of the plan year if they have any employees in a state listed in the notice.

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Topics: DOL, CHIP, compliance recap