The Affordable Care Act (ACA) requires health plans and health insurance issuers to provide applicants and enrollees with a concise document providing simple and consistent information about health plan benefits and coverage. This document, which is called a summary of benefits and coverage (SBC), is intended to help health plan consumers better understand the coverage [...]

The IRS recently updated its guidelines on “Audit Techniques and Tax Law to Examine COBRA Cases (Continuation of Employee Health Care Coverage).” These Guidelines are used by field agents when examining plans for COBRA compliance. Therefore, they are a useful tool to help employers conduct “self audits” of their COBRA policies and procedures. Failure to [...]

The Affordable Care Act (ACA) created the Patient-Centered Outcomes Research Institute (Institute) to help patients, clinicians, payers and the public make informed health decisions by advancing comparative effectiveness research. The Institute’s research is to be funded, in part, by fees paid by health insurance issuers and sponsors of self-insured health plans. On April 17, 2012, [...]

Recently, we reported that the Senate had passed a Highway Funding Bill with a provision that would put employees who use public transit on equal footing with employees who drive to work and need to cover parking costs. This equity was derived from capping both types of pre-tax transportation benefits at $240 per month. Initially, [...]

The U.S. Department of Labor’s Office of Chief Accountant has recently begun issuing Requests for Clarification (“Requests”) to certain health and welfare plan administrators regarding information provided in their Form 5500 filings. Health and welfare plans that have received these Requests have been funded through a combination of insured and self-insured coverages, which is not [...]

On March 12, 2012, the U.S. Department of Health and Human Services (HHS) released a final rule on the Exchanges, to be published in the Federal Register on March 27, 2012. The final rule combines policies from two separate Notices of Proposed Rulemaking (NPRMs) published in summer 2011. It sets forth: • The minimum federal [...]

Health care reform imposes a $2,500 annual limit on salary reduction contributions to health flexible spending arrangements (FSAs) offered under cafeteria plans. The limit applies to both grandfathered and non-grandfathered health FSAs. This new limit is effective for taxable years beginning after Dec. 31, 2012. Beginning with the 2014 tax year, the $2,500 limit will [...]

The health care reforms made by the Patient Protection and Affordable Care Act (PPACA or Affordable Care Act) have staggered effective dates, with many important provisions becoming effective in 2014. The Departments of Health and Human Services, Labor and Treasury (Departments) are working on regulations and other guidance to implement the 2014 health care reform [...]

It was announced that the sum total of all MLR rebates for 2011 will be about $323 million. Based on the total insured population, that means that the average rebate is less than $2 a person. While MLR limits are generally seen as a good thing for employers, one has to wonder if as much [...]

This provision of PPACA requires large employers with 200 or more full time employees to automatically enroll new employees in one of the employer’s health benefit plans, subject to waiting period rules, and to continue the coverage of existing employees in a health plan, unless an employee opts out. Previously, DOL had indicted that employers [...]