DEPARTMENTS RELEASE FINAL ACA RULES ON MULTIPLE TOPICS
|
|
- Jodie Blair
- 5 years ago
- Views:
Transcription
1 Finalizing the ACA Stew of Rules Integrating Marriage and HRAs Just Kidding: No More Extended Form 5500 Extensions DEPARTMENTS RELEASE FINAL ACA RULES ON MULTIPLE TOPICS On November 18, 2015, the Departments of Labor, Treasury, and Health and Human Services (hereinafter referred to as Departments ) released final regulations on multiple topics in relation to the legislation commonly referred to as the Affordable Care Act (ACA). Highlights of the final regulations are contained below. Grandfathered Plans Employers wishing to preserve their grandfathered plan status (in order to avoid some of the ACA requirements and regulations) must do the following with their health plan: 1) A group health plan must include a statement that it is a grandfathered plan in its Summary of Benefits and Coverage (SBC), and it must provide contact information for any questions or comments in relation to the grandfathered status 2) The group health plan cannot eliminate all or substantially all of its benefits to diagnose or treat any particular condition, which is a facts and circumstances test Regulations clarify that the addition of newly contributing employers to a grandfathered multiemployer plan will not affect the plan s grandfathered status. In addition, regulations clarify that if a grandfathered plan previously had fixed-dollar employee contributions, or no employee contributions toward the plan, the plan will continue to be treated as a grandfathered health plan (even if the employer contribution changes), so long as the fixed dollar employee contribution doesn t change or the employee still does not contribute towards their benefits. Lifetime and Annual Dollar Limits Some clarification on the issue of lifetime and annual dollar maximums on Essential Health Benefits (EHB) was included in the final rules. The following are highlights: 1) EHBs shall be defined as either those EHB base-benchmark plans that were selected by the plan (whether by State selection or by default of the EHB base-benchmark plan for the State), and not all plans that are potentially authorized 2) Group/grandfathered individual plans that are not required to provide EHBs may select among any of the 51 EHB base-benchmark plans selected by a State or the District of Columbia, in addition to the Federal Essential Health Benefit Plan (FEHBP) base-benchmark plan, beginning on or after January 1, ) The annual dollar limit prohibition applies to a health Flexible Spending Account (Health FSA) that is not offered through a cafeteria plan 4) Certain account based plans, including FSAs, medical reimbursement plans, and HRAs, may be integrated with other group health plan coverage Page 1
2 Departments Release Final ACA Rules on Multiple Topics (Continued) Lifetime and Annual Dollar Limits (Continued) 5) An HRA will be treated as forfeited or waived, even if the waiver or forfeiture amounts/reimbursements may be reinstated upon a fixed date, a participant s death, or the earlier of the two events, so long as the amounts are irrevocable until the earlier occurrence of either event 6) HRAs may be integrated with Medicare for employers with fewer than 20 employees (because these size employers are not required to offer their group health plan coverage to employees who are Medicare eligible) Rescissions Group health plans and insurance issuers may not rescind the coverage of a plan participant except in the event of fraud or intentional misrepresentation of material fact by the plan participant. The following items in relation to rescission were clarified in the final regulations: 1) The term material fact will continue to be vaguely defined by the Departments, which seems to indicate that plan sponsors may have some discretion in defining what a material fact would be to cause a rescission of a plan participant s coverage 2) If an employee initiates a retroactive cancellation or discontinuance of coverage, this would not be considered a rescission, so long as the employee did so under no influence or from threat of retaliation by the plan sponsor, issuer, employer or health plan 3) A retroactive cancellation or discontinuance of coverage initiated by the Exchange is not a rescission 4) Rescissions are subject to internal claims and external review processes 5) A retroactive termination of coverage due to non-payment of COBRA premiums is permissible, and is not considered a rescission of coverage Dependent Coverage until Age 26 Group health plans and insurance carriers offering health insurance that covers children, must make such coverage available to children until age 26. To provide clarity on this topic however, the final regulations state that eligibility restrictions such as requiring children to work, live, or reside in the service area cannot be a requirement for their eligibility. The health plan can still provide coverage within a limited service area, but cannot require that the child be located in that service area. Patient Protections under a Health Plan Clarification on rules in relation to designations of primary care providers and emergency services for non-grandfathered health plans were also included in the final regulations. Below are a few highlights in relation to that section of the ACA: 1) The term primary care provider shall be defined by the plan or policy terms, in accordance with applicable state law 2) If a plan or issuer requires the designation of a primary care provider for a child, the plan or issuer must allow any physician who specializes in pediatric care (including specialists) who are in-network and available, to be designated as a primary care provider 3) All women, regardless of age, are ensured direct access to an OB/GYN provider 4) Health plans may apply reasonable and appropriate geographic limitations on which primary care providers may be designated as such, in that geographic location 5) Emergency care may not limit treatment of an emergency to within 24 hours of the onset of the condition. In addition, a health plan must provide coverage for emergency services, without any time limit as to when such treatment should have been sought Action Required Although the final rules predominantly adopt previously proposed and interim final rules on the ACA market reforms, plan sponsors should still review their health plans to ensure that the above clarifications are incorporated into the health plan for compliance purposes. For the complete details, see: Final Regulations: Page 2
3 IRS ISSUES MEMORANDUM OPINION ON INTEGRATED HRAs WITH SPOUSAL COVERAGE On November 20, 2015, the Office of Chief Counsel of the Internal Revenue Service (hereinafter referred to as IRS ) released a memorandum on the issue of Internal Revenue Code (IRC) Section 105 or IRC Section 106 payments for the cost of health insurance coverage to the employee through his or her spouse s employer group health plan. Several scenarios were outlined, and the taxation consequences of each scenario are outlined below. General Rule An employer may exclude from an employee s income (under IRC section 105 or Section 106) payments for the cost of health insurance coverage provided to the employee through his or her spouse s employer group health plan, so long as the cost of the employee s coverage through the spouse s employer group health plan is paid for on an after-tax basis. This payment may be made by an employer either in part, or in whole. Different Scenarios of Reimbursement Situation 1 employer also provides an arrangement where A may seek reimbursement for the cost of coverage incurred by A s spouse (spouse B) for A s coverage under B s employer sponsored plan. Under B s employer sponsored plan, an employee participating in the plan must make either a $100 per month after-tax contribution to B s employer sponsored plan for self-only coverage, or an after-tax contribution of $175 per month for other than self-only coverage. B elects other than self-only coverage, at the cost of $175 of post-tax monies. A substantiates to A s employer that B s employer deducts on a post-tax basis $175 for other than self-only coverage out of B s paycheck, of which $75 is for the cost of A s coverage on B s employer sponsored health plan. A receives $75, for the reimbursement of A s share of premium cost at B s employer. The amount of $75 may be excluded from A s income, in addition to FICA taxes, FUTA taxes, and Federal income tax withholding purposes. Situation 2 employer also provides an arrangement where A may seek reimbursement for the cost of coverage incurred by A s spouse (spouse B) for A s coverage under B s employer sponsored plan. Under B s employer sponsored plan, an employee participating in the plan must make either a $100 per month pre-tax (i.e., excluded from income under Section 125) contribution to B s employer sponsored plan for self-only coverage, or a pre-tax (i.e., excluded from income under Section 125) contribution of $175 per month for other than self-only coverage. B elects other than self-only coverage, at the cost of $175 of pre-tax (i.e., excluded from income under Section 125) monies. A substantiates to A s employer that B s employer deducts on a pre-tax basis $175 for other than self-only coverage out of B s paycheck, of which $75 is for the cost of A s coverage on B s employer sponsored health plan on a pre-tax basis. A receives $75, for the reimbursement of A s share of premium cost at B s employer. The amount of $75 may not be excluded from A s income, and is not excluded as income for FICA taxes, FUTA taxes, and Federal income tax withholding purposes, because B s employer sponsored plan allows pre-tax contributions for premiums under Section 125. Page 3
4 IRS Issues Memorandum Opinion on Integrated HRAs with Spousal Coverage (Continued) Situation 3 employer also provides an arrangement through a Health Reimbursement Arrangement (HRA) where the HRA reimburses A the cost of coverage incurred by B for A s coverage under B s employer sponsored plan. Under B s employer sponsored plan, an employee participating in the plan must make either a $100 per month after-tax contribution to B s employer sponsored plan for self-only coverage, or an after-tax contribution of $175 per month for other than self-only coverage. B elects other than self-only coverage, at the cost of $175 of post-tax monies. A substantiates to A s employer that B s employer deducts on a post-tax basis $175 for other than self-only coverage out of B s paycheck, of which $75 is for the cost of A s coverage on B s employer sponsored health plan. A receives $75 through an HRA, for the reimbursement of A s share of premium cost at B s employer. The amount of $75 may be excluded from A s income, in addition to FICA taxes, FUTA taxes, and Federal income tax withholding purposes. Situation 4 employer also provides an arrangement through an HRA where the HRA reimburses A the premium cost incurred by B for A s coverage under B s employer sponsored plan, in addition, the HRA reimburses any unreimbursed medical expenses incurred by A or B under B s employer sponsored plan. Under B s employer sponsored plan, an employee participating in the plan must make either a $100 per month pre-tax contribution to B s employer sponsored plan for self-only coverage, or a pre-tax contribution of $175 per month for other than self-only coverage. B elects other than self-only coverage, at the cost of $175 of pre-tax monies. A substantiates to A s employer that B s employer deducts on a pre-tax basis $175 for other than self-only coverage out of B s paycheck, of which $75 is for the cost of A s coverage on B s employer sponsored plan. A receives $75 through an HRA, for the reimbursement of A s share of premium cost at B s employer. The amount of $75 may not be excluded from A s income, and is not excluded as income for FICA taxes, FUTA taxes, and Federal income tax withholding purposes, because B s employer sponsored plan allows pre-tax contributions for premiums under Section 125. Situation 5 employer also provides an arrangement through an HRA where the HRA reimburses A the premium cost incurred by B for A s coverage under B s employer sponsored plan, in addition, the HRA reimburses any unreimbursed medical expenses incurred by A or B under B s employer sponsored plan. Under B s employer sponsored plan, an employee participating in the plan must make either a $100 per month post-tax contribution to B s employer sponsored plan for self-only coverage, or a post-tax contribution of $175 per month for other than self-only coverage. B elects other than self-only coverage, at the cost of $175 of post-tax monies. A substantiates to A s employer that B s employer deducts on a post-tax basis $175 for other than self-only coverage out of B s paycheck, of which $75 is for the cost of A s coverage on B s employer sponsored plan. A receives $75 through an HRA, for the reimbursement of A s share of premium cost at B s employer. The amount of $75 may be excluded from A s income, and is excluded as income for FICA taxes, FUTA taxes, and Federal income tax withholding purposes. Page 4
5 IRS Issues Memorandum Opinion on Integrated HRAs with Spousal Coverage (Continued) Situation 6 employer also provides an arrangement through an HRA where the HRA only reimburses A and B any unreimbursed medical expenses incurred by A or B, and does not reimburse A s share of premium cost to B. A incurs $1,000 of unreimbursed medical expenses, which does not include the premium cost of A s coverage under B s employer sponsored plan. A receives $1,000 through A s employer sponsored HRA, for the reimbursement of A s share of unreimbursed medical costs. The amount of $1,000 may be excluded from A s income, and is excluded as income for FICA taxes, FUTA taxes, and Federal income tax withholding purposes. Action Required Employers who reimburse an employee s cost of premiums for a spouse s employer sponsored plan pre-tax, through an integrated HRA, should ensure that the employee s spouse s employer plan is paid for on a post-tax basis. For the complete details, see: IRS Memorandum: EXTENSION PERIOD FOR FILING FORM 5500 REPEALED BEFORE EFFECTIVE DATE Summary Legislation, enacted in July of 2015, extended the extension deadline for filing a Form 5500 from 2.5 months to 3.5 months. However, that portion of the legislation was repealed at the beginning of December through the Fixing America s Surface Transportation Act. As a result, the extension deadline is again set at 2.5 months from the original filing deadline, rather than 3.5 months. Action Required Employers who were relying on the 3.5 month extension for filing Form 5500s should take action now to ensure they file applicable Form 5500s within 2.5 months of the original deadline. For the complete details, see: Fixing America s Surface Transportation Act: Page 5
6 QUESTION OF THE MONTH Q: What records does ERISA require us to maintain for our employee welfare benefit plans, and for how long? A: Exactly what records need to be retained under ERISA will depend on the plan s characteristics. ERISA 107 requires retaining records sufficient to document the accuracy and completeness of information required to be reported on Form (Records must be maintained by the party responsible for filing or certifying the relevant information the plan administrator is generally responsible for filing Form 5500 and thus will have the primary record retention obligation, but other parties may also have record retention obligations.) Even for ERISA plans that are exempt from filing Form 5500 (or that qualify for simplified reporting), records relating to information that would be reportable on Form 5500 absent the filing exemption must be maintained. (It is also advisable to keep records documenting the plan s eligibility for the exemption or simplified reporting.) The records that support (or would support) Form 5500 information will vary according to the size and type of plan in question and may include items such as checks, invoices, contracts, agreements, receipts, claim records, and payroll information. Notably, summaries are generally not sufficient the actual records must be retained. ERISA permits records to be retained electronically if certain requirements are met. As for how long to keep these records, ERISA 107 requires that they be retained for a period of not less than six years after the Form 5500 filing date (or, for plans exempt from the filing requirement, when the filing would have been due absent the exemption). Because the Form 5500 due date is well after the end of the plan year (the last day of the seventh month after the close of the plan year later if the plan files an extension), the effective retention period is eight years from the beginning of the relevant plan year. Finally, note that additional considerations will affect plan recordkeeping, such as requirements under the Code and other laws, demonstrating compliance with applicable laws and regulations, and keeping records in anticipation of possible litigation. Source: Thomson Reuters/EBIA Page 6
Departments Issue Final ACA Market Reforms Rule
Authors: Sravya Boppana, Jon Breyfogle, Lisa Campbell, Tamara Killion, Emily Lechner If you have questions, please contact your regular Groom attorney or one of the attorneys listed below: Kathryn Bjornstad
More information4/13/16. Provided by: Zywave W. Innovation Drive, Suite 300 Milwaukee, WI
4/13/16 Provided by: Zywave 10100 W. Innovation Drive, Suite 300 Milwaukee, WI 53226 Email: marketing@zywave.com Design 2015 Zywave, Inc. All rights reserved. Table of Contents Introduction... 3 Plan Design
More information1/5/16. Provided by: The Lank Group Winterthur Close Kennesaw, GA Tel: Design 2015 Zywave, Inc. All rights reserved.
1/5/16 Provided by: The Lank Group 2971 Winterthur Close Kennesaw, GA 30144 Tel: 770-683-6423 Design 2015 Zywave, Inc. All rights reserved. Table of Contents Introduction... 3 Plan Design and Coverage
More information4/13/16. Provided by: KRA Agency Partners, Inc. 99 Cherry Hill Road, Suite 200 Parsippany, NJ Tel:
4/13/16 Provided by: KRA Agency Partners, Inc 99 Cherry Hill Road, Suite 200 Parsippany, NJ 07054 Tel: 973-588-1800 Design 2015 Zywave, Inc. All rights reserved. Table of Contents Introduction...3 Plan
More informationImportant Effective Dates for Employers and Health Plans
Brought to you by Hipskind Seyfarth Risk Solutions Important Effective Dates for Employers and Health Plans On March 23, 2010, President Obama signed the health care reform bill, or Affordable Care Act
More informationHealth Care Reform Toolkit Large Employers
Health Care Reform Toolkit Large Employers Table of Contents Introduction... 3 Plan Design and Coverage Issues: 2014 and Beyond... 4 Employer Obligations... 11 Notice and Disclosure Requirements... 19
More informationIntroduction Notice and Disclosure Requirements Plan Design and Coverage Issues: Prior to
8/22/13 Table of Contents Introduction... 3 Notice and Disclosure Requirements... 4 Plan Design and Coverage Issues: Prior to 2014... 10 Plan Design and Coverage Issues: 2014 and Beyond... 12 Wellness
More informationNational Health Insurance Reform
MAY2010 National Health Insurance Reform Impact Year by Year With the passage of National Health Insurance Reform it is crucial that employers and plan sponsors have clear information about the impact
More informationHealth Care Reform: Legislative Brief Important Effective Dates for Employers and Health Plans
Health Care Reform: Legislative Brief Important Effective Dates for Employers and Health Plans On March 23, 2010, President Obama signed the health care reform bill, or Affordable Care Act (ACA), into
More informationImpacts for Employers
FACT SHEET Reimbursement Vehicles and the ACA: Impacts for Employers The IRS issued guidance on the application of certain provisions of the Affordable Care Act (ACA) to employer health care reimbursement
More informationELWOOD STAFFING SERVICES, INC. COLUMBUS IN
ELWOOD STAFFING SERVICES, INC. COLUMBUS IN Dental Benefit Summary Plan Description 7670-09-411299 Revised 01-01-2017 BENEFITS ADMINISTERED BY Table of Contents INTRODUCTION... 1 PLAN INFORMATION... 2 SCHEDULE
More informationHEALTH CARE REFORM: EMPLOYER ACTION OVERVIEW
CORPORATE BENEFITS COMPLIANCE WHITE PAPER HEALTH CARE REFORM: EMPLOYER ACTION OVERVIEW MARCH 23, 2010 EMPLOYER ACTION REQUIRED NOTES Nursing Mothers Employers must provide a reasonable break time for non-exempt
More informationIn Effect Now In Effect September 23, 2010 In Effect January 1, 2011
informed on reform KEEPING YOU UP-TO-DATE ON THE PPACA New Health Care s Effective by January 1, 2011 Last updated: September 14, 2010 The following chart outlines provisions of the new Patient Protection
More informationSUMMARY PLAN DESCRIPTION for the Verso Corporation Health and Welfare Benefit Plan
SUMMARY PLAN DESCRIPTION for the Verso Corporation Health and Welfare Benefit Plan Represented Employees 2018 This document, together with the benefit booklets listed in the section entitled Benefit Programs
More informationSection 125 Cafeteria Plans Overview
Provided by Sullivan Benefits Section 125 Cafeteria Plans Overview A Section 125 plan, or a cafeteria plan, allows employees to pay for certain benefits on a pre-tax basis. Specifically, employers use
More informationARMSTRONG INTERNATIONAL, INC. THREE RIVERS MI
ARMSTRONG INTERNATIONAL, INC. THREE RIVERS MI Dental Booklet Revised 01-01-2016 BENEFITS ADMINISTERED BY Table of Contents INTRODUCTION... 3 PLAN INFORMATION... 4 SCHEDULE OF BENEFITS... 6 OUT-OF-POCKET
More informationExcise Taxes for Group Health Plan Violations
Provided by BBP Admin Excise Taxes for Group Health Plan Violations Group health plans are responsible for compliance with a number of federal laws. If a group health plan does not comply with certain
More informationHealth Care Reform Update
Updated March 9, 2011 Health Care Reform Update Health Care Reform Timeline for Employer-Sponsored Plans This timeline provides some of the key dates associated with the Patient Protection and Affordable
More informationAscension Health FLEXIBLE SPENDING ACCOUNT PLAN SUMMARY PLAN DESCRIPTION ("SPD") St. Thomas Health Services
Ascension Health FLEXIBLE SPENDING ACCOUNT PLAN SUMMARY PLAN DESCRIPTION ("SPD") St. Thomas Health Services TABLE OF CONTENTS INTRODUCTION TO THE FLEXIBLE SPENDING ACCOUNT PLAN SUMMARY PLAN DESCRIPTION...
More informationCLICK HERE to return to the home page
CLICK HERE to return to the home page IRS Notice 2013-54 Application of Market Reform and other Provisions of the Affordable Care Act to HRAs, Health FSAs, and Certain other Employer Healthcare Arrangements
More informationFlexible Spending and Premium Cafeteria Plan Summary Plan Description And Plan Document
Flexible Spending and Premium Cafeteria Plan Summary Plan Description And Plan Document 7670-02-411309 Revised 01-01-2016 BENEFITS ADMINISTERED BY Table of Contents INTRODUCTION... 1 PLAN INFORMATION...
More informationEmployer Mandate: Employer Action Overview
HEALTH CARE REFORM Employer Mandate: Page 2 of 11 Immediatemmediate Employer Action Required Notes Nursing Mothers Employers must provide a reasonable break time for non-exempt employees who are nursing
More informationWPELRA ACA Update. January 21, Auntone A. Kelly & Kathy Schwappach v
WPELRA ACA Update January 21, 2016 Auntone A. Kelly & Kathy Schwappach 5560510v1.96030.902 Copyright 2015 by The Segal Group, Inc. All rights reserved. Agenda Recent U.S. Supreme Court Decisions Legislative
More informationEmployee Benefits Compliance Checklist for Large Employers
Brought to you by Ardent Solutions Employee Benefits Compliance Checklist for Large Employers Federal law imposes numerous requirements on the group health coverage that employers provide to their employees.
More informationHealth Care Reform Checklist
ompliance dashboard Health Care Reform Checklist COMPLIANCE REVIEW: Past Requirements or Provisions (2010 to 2013) Provide Dependent Coverage for Children Under Age 26 regardless of marital or student
More informationTHE LINDSEY WILSON COLLEGE CAFETERIA PLAN SUMMARY PLAN DESCRIPTION
THE LINDSEY WILSON COLLEGE CAFETERIA PLAN SUMMARY PLAN DESCRIPTION Introduction Lindsey Wilson College (the Employer ) sponsors the Lindsey Wilson College Cafeteria Plan (the Cafeteria Plan ) that allows
More informationCafeteria Plans: Participant Contributions
Cafeteria Plans: Participant Contributions Cafeteria plans, or plans governed by IRS Code Section 125, allow employees to pay for expenses such as health insurance with pre-tax dollars. Employees are given
More informationSelf-Compliance Tool for Part 7 of ERISA: Affordable Care Act Provisions
Self-Compliance Tool for Part 7 of ERISA: Affordable Care Act Provisions INTRODUCTION While this self-compliance tool does not necessarily cover all the specifics of these laws, it is intended to assist
More informationHealth Care Reform. Employer Action Overview
Health Care Reform Page 2 of 10 Health Care Reform Immediatemmediate Employer Action Required Notes Nursing Mothers Employers must provide a reasonable break time for employees who are nursing mothers
More informationE.L. Hollingsworth & Co Cafeteria Plan SUMMARY PLAN DESCRIPTION
E.L. Hollingsworth & Co Cafeteria Plan SUMMARY PLAN DESCRIPTION Effective August 1, 2013 Summary Plan Description With Premium Payment, and Health FSA Components Table of Contents Article I 1 INTRODUCTION
More informationHealth Care Reform Health Plans Overview
Health Care Reform Health Plans Overview Topics Status of health care reform Grandfathered plans Timeline for compliance Health Care Reform What is It? Patient Protection and Affordable Care Act (PPACA)
More informationEmployer Healthcare Reform Requirements in the Near-Term
Employer Healthcare Reform Requirements in the Near-Term On March 23, 2010, President Obama signed into law The Patient Protection and Affordable Care Act (H.R. 3590). As of this writing, 1 the Congress
More informationLEGAL ALERT. June 28, 2010
LEGAL ALERT June 28, 2010 PPACA Rules on Preexisting Condition Exclusions, Lifetime and Annual Limits, Rescissions of Coverage, and Patient Protections Issued On June 22, 2010, the tri-agency task force
More informationGLOSSARY OF KEY AFFORDABLE CARE ACT AND COMMON HEALTH PLAN TERMS
GLOSSARY OF KEY AFFORDABLE CARE ACT AND COMMON HEALTH PLAN TERMS Note: in the event of any conflict between this glossary and your plan document/summary plan description (SPD) or policy/certificate, the
More informationHEALTH CARE REFORM: THE EMPLOYER PERSPECTIVE
www.bakerdaniels.com HEALTH CARE REFORM: THE EMPLOYER PERSPECTIVE Prepared and Presented by: Michael J. Nader Baker & Daniels LLP 111 East Wayne Street, Suite 800 Fort Wayne, IN 46802 260.460.1743 michael.nader@bakerd.com
More informationGroup Health Plan Enrollment Rules
Provided by Power Kunkle Benefits Consulting Group Health Plan Enrollment Rules Employers that sponsor group health plans have some different options available to them for designing their plans enrollment
More informationHealth Plan Enrollment Rules
Provided by Sullivan Benefits Health Plan Enrollment Rules Employers that sponsor group health plans have some different options available to them for designing their plans enrollment process. When it
More informationAn Employer's Update on Employee Benefits
An Employer's Update on Employee Benefits August 14, 2015 Presented by: Andrea Bailey Powers 205.244.3809 apowers@bakerdonelson.com SAME GENDER SPOUSES Tax-Qualified Retirement Plans Survivor/Beneficiary
More informationTHE CENTRAL METHODIST UNIVERSITY CAFETERIA PLAN SUMMARY PLAN DESCRIPTION
THE CENTRAL METHODIST UNIVERSITY CAFETERIA PLAN SUMMARY PLAN DESCRIPTION Introduction Central Methodist University (the Employer ) sponsors the Central Methodist University Cafeteria Plan (the Cafeteria
More informationProposed Regulations Address Preexisting Condition Exclusions, Lifetime and Dollar Limits, Rescissions & Patient Protections Under the Health Care Act
June 23, 2010 Proposed Regulations Address Preexisting Condition Exclusions, Lifetime and Dollar Limits, Rescissions & Patient Protections Under the Health Care Act As touted in the HealthReform.gov Fact
More informationWASHINGTON AND LEE UNIVERSITY EMPLOYEE HEALTH AND WELFARE PLAN PLAN DOCUMENT AND SUMMARY PLAN DESCRIPTION
WASHINGTON AND LEE UNIVERSITY EMPLOYEE HEALTH AND WELFARE PLAN PLAN DOCUMENT AND SUMMARY PLAN DESCRIPTION This document is provided for informational purposes and to comply with certain requirements of
More informationACA Violations Penalties and Excise Taxes
Provided by Propel Insurance ACA Violations Penalties and Excise Taxes The Affordable Care Act (ACA) includes numerous reforms for group health plans and creates new compliance obligations for employers
More informationNew Health Care Laws: Top 10 Things Employers Need to Consider Before 2012
New Health Care Laws: Top 10 Things Employers Need to Consider Before 2012 Published on Alvarez & Marsal (https://www.alvarezandmarsal.com) On March 23, 2010, President Obama signed into law H.R. 3590,
More informationUnderstanding & Addressing Your 2019 Health and Welfare Benefits Compliance Obligations
Understanding & Addressing Your 2019 Health and Welfare Benefits Compliance Obligations NOVEMBER 15, 2018 PRESENTERS Carl Pilger, Esq. Director, National Employee Benefit Compliance Services EPIC Insurance
More informationHealth Care Reform Timeline Last Updated: March 12, 2014
Health Care Reform Timeline Last Updated: March 12, 2014 On March 23, 2010, President Obama signed into law the Patient Protection and Affordable Care Act ( PPACA or ACA or Health Care Reform ). Health
More informationTHE WILKES UNIVERSITY CAFETERIA PLAN SUMMARY PLAN DESCRIPTION
THE WILKES UNIVERSITY CAFETERIA PLAN SUMMARY PLAN DESCRIPTION Introduction Wilkes University (the Employer ) sponsors the Wilkes University Cafeteria Plan (the Cafeteria Plan ) that allows eligible Employees
More informationHealth Care Reform at-a-glance
Health Care Reform at-a-glance August 2015 Table of Contents Employer mandate...3 Individual mandate...3 Health plan provisions applying to both grandfathered and non-grandfathered employer plans...4 Health
More informationHealtH Care reform 2012 and beyond
HealtH Care reform 2012 and beyond A guide to the major provisions of health care reform legislation affecting employers in 2012 and 2013 and a timeline of the reforms to be introduced through 2018. Employers
More informationSummary Plan Description
Summary Plan Description For the Allegheny College Section 125 Plan Amended and Restated Effective July 1, 2014 This document with the attached documents listed on the final page, constitute the written
More informationSAMPLE CAFETERIA PLAN
HR COMPLIANCE CENTER Cafeteria plans are governed by Internal Revenue Code 125 requiring employees to make irrevocable elections before the start of the plan year. Midyear changes are prohibited except
More informationTHE CAFETERIA PLAN SUMMARY PLAN DESCRIPTION FOR WHEELING JESUIT UNIVERSITY
THE CAFETERIA PLAN SUMMARY PLAN DESCRIPTION FOR WHEELING JESUIT UNIVERSITY Page 1 of 42 Introduction Wheeling Jesuit University (the Employer ) sponsors the Wheeling Jesuit University Cafeteria Plan (the
More informationTender Touch Rehab Services LLC Flexible Benefits Plan SUMMARY PLAN DESCRIPTION. Effective January 1, 2017
Tender Touch Rehab Services LLC Flexible Benefits Plan SUMMARY PLAN DESCRIPTION Effective January 1, 2017 Summary Plan Description With Premium Payment, Health FSA, and DCAP Components Table of Contents
More informationCENTRAL MAINE HEALTHCARE CORPORATION LEWISTON ME
CENTRAL MAINE HEALTHCARE CORPORATION LEWISTON ME Flexible Spending Summary Plan Description 7670-03-150028 BENEFITS ADMINISTERED BY Amendment #1 CENTRAL MAINE HEALTHCARE CORPORATION January 1, 2008 The
More informationCollege for Creative Studies Cafeteria Plan SUMMARY PLAN DESCRIPTION. Effective January 1, 2017
College for Creative Studies Cafeteria Plan SUMMARY PLAN DESCRIPTION Effective January 1, 2017 Summary Plan Description With Premium Payment, Health FSA, and DCAP Components Table of Contents Article I
More informationHealth Care Reform Overview
Published on : December 06, 2010 Health Care Reform Overview President Obama signed the Patient Protection and Affordable Care Act into law on March 23, 2010. The law was almost immediately amended by
More informationSection 125: Cafeteria Plans Overview. Presented by: Touchstone Consulting Group
Section 125: Cafeteria Plans Overview Presented by: Touchstone Consulting Group Introduction Today s Agenda Introduction to Cafeteria Plans Eligibility Rules Qualified Benefits Contributions Participant
More informationSBAM Health & Welfare Benefits Compliance Checklist Including ERISA, ACA, Section 125, HIPAA, and other applicable federal statutes and regulations
SBAM Health & Welfare Benefits Compliance Checklist Including ERISA, ACA, Section 125, HIPAA, and other applicable federal statutes and regulations As an employer that sponsors a group benefits program,
More informationGuide to Participant Notices
Guide to Participant s What What Groups Description Who When Distributed Annually Group health plan sponsors must provide a Medicare-eligible notice of creditable or non-creditable employees who are prescription
More informationHealthcare Reform Better Care Reconciliation Act Repeal & Replace
BCRA AHCA American Health Care Act Healthcare Reform Better Care Reconciliation Act Repeal & Replace ACA HCR Affordable Care Act BCRA, AHCA and ACA On June 22, 2017, Senate Republicans released the Better
More informationBENEFITS REQUIREMENTS
Client Name: No. of Employees: Note: This list is for use by employers with 50 or more employees. Plan Year: BENEFITS REQUIREMENTS Employer Payment Plans Prohibited. Ensure that an employer payment plan
More informationThe Employer s Essential HEALTH CARE REFORM COMPLIANCE CHECKLIST 2014
The Employer s Essential HEALTH CARE REFORM COMPLIANCE CHECKLIST 2014 HEALTH CARE REFORM COMPLIANCE CHECKLIST: 2014 2 The #1 Online Health Benefits Solution Zane Benefits was founded in 2006 to revolutionize
More informationSection 125: Cafeteria Plan Common Questions
Provided by New Agency Partners Section 125: Cafeteria Plan Common Questions A Section 125 plan, or a cafeteria plan, allows employers to provide their employees with a choice between cash and certain
More informationHealth Flexible Spending Account Issues
Health Flexible Spending Account Issues Larry Grudzien Attorney at Law ABOUT LARRY Lawrence (Larry) Grudzien, JD, LLM is an attorney practicing exclusively in the field of employee benefits. He has experience
More informationAFFORDABLE CARE ACT: STATUS CHART Health Plans
AFFORDABLE CARE ACT: STATUS CHART Health Plans July 2017 TODD MARTIN, PARTNER 612.335.1409 todd.martin@stinson.com Table of Contents Page ACA Coverage Mandates... 1 ACA Insurance Market Rules... 5 ACA
More informationBORGWARNER FLEXIBLE BENEFITS PLAN SUMMARY PLAN DESCRIPTION 2018
BORGWARNER FLEXIBLE BENEFITS PLAN SUMMARY PLAN DESCRIPTION 2018 Table of Contents Pages INTRODUCTION...1 BENEFITS AND ELIGIBILITY...1 ENROLLMENT AND ELECTION OF BENEFITS...8 HEALTH CARE FLEXIBLE SPENDING
More informationEXPERT UPDATE. Compliance Headlines from Henderson Brothers:.
EXPERT UPDATE Compliance Headlines from Henderson Brothers:. Health Care Reform Timeline Health Care Reform Timeline This Henderson Brothers Summary provides a timeline of the of key reform provisions
More informationDefined Contribution What s Legal, What s Not?
Finally, some answers Defined Contribution What s Legal, What s Not? PURPOSE AND OVERVIEW Eric Johnson 817-366-7536 eric@comedyce.com PURPOSE AND OVERVIEW Working Together This Technical Release provides
More information4 The Impact Of Federal Health Care Reform On Employers And Employer-Sponsored Group Health Plans: An Overview And Retrospective
4 The Impact Of Federal Health Care Reform On Employers And Employer-Sponsored Group Health Plans: An Overview And Retrospective Alden J. Bianchi * Signed into law on March 23, 2010, following more than
More informationYear-end Legislation and Agency Guidance Affects Health and Welfare Plans
Authors: Kathryn Bjornstad Amin, Lisa Campbell, Rachel Leiser Levy, Seth Perretta If you have questions, please contact your regular Groom attorney or one of the attorneys listed below: Kathryn Bjornstad
More informationQuick Reference Guide: Key Health Care Reform Requirements Affecting Plan Sponsors
Quick Reference Guide: Key Health Care Reform Requirements Affecting Plan Sponsors The following is a brief summary of some of the key requirements affecting group health plan sponsors. This is only a
More informationHEALTH CARE REFORM PROVISIONS BY TYPE AND SIZE OF PLAN Last Rev. July 14, 2014
2010: First Plan Year on or after September 23, 2010 Extension of dependent coverage up to age 26 No pre-existing condition exclusions for enrollees under age 19 No lifetime dollar limits on "essential
More informationFAQs About the Affordable Care Act Implementation Part II.
FAQs About the Affordable Care Act Implementation Part II http://www.dol.gov/ebsa/faqs/faq-aca2.html FAQs About the Affordable Care Act Implementation Part II GRANDFATHERED HEALTH PLANS... 1 Q1: OUR COMPANY
More informationProposed Rules Allow the Use of HRAs to Pay For Individual Market Coverage
Proposed Rules Allow the Use of HRAs to Pay For Individual Market Coverage PUBLISHED: October 29, 2018 AUTHORS: Katie Bjornstad Amin, Christine Keller, Rachel Leiser Levy, Stephen Pennartz, Seth Perretta,
More information5GBenefits, LLC Your Health Care Reform Partner
5GBenefits, LLC Your Health Care Reform Partner Are you in compliance with health care reform regulations? We can help you stay on top of health care reform in order to avoid penalties from legislative
More informationEmployee Benefits Compliance Checklist for Large Employers
: Provided by [B_Officialname] Employee Benefits Compliance Checklist for Large Employers Federal law imposes numerous requirements on the group health coverage that employers provide to their employees.
More informationComparison of Healthcare Reimbursement Programs
June 2016 Presented by Lockton Companies L O C K T O N C O M P A N I E S Table of Contents General 1 Eligibility. 3 Contributions 7 Distributions.. 10 Healthcare Reform Implications. 12 Miscellaneous 15
More informationPOLICY AND REGULATIONS MANUAL HEALTH AND RELATED BENEFITS
Page Number: 1 of 24 TITLE: HEALTH AND RELATED BENEFITS PURPOSE: To provide an overview of the health and related benefits offered to Benefit Eligible Employees, Benefit Eligible Retirees, and their Benefit
More informationHealth Care Reform Update. April 2013
Health Care Reform Update April 2013 2013 Compliance Issues Summary of Benefits and Coverage Simple explanation of benefits and costs 4 double sided pages, 12 point or larger font Can provide in paper
More informationHealth Care Reform Compliance: An Employer Perspective
Health Care Reform Compliance: An Employer Perspective L& E Breakfast Briefing February 20, 2014 Houston, Texas Presented by: Andrea Bailey Powers 205.244.3809 apowers@bakerdonelson.com Select ACA Provisions
More informationHIPAA Special Enrollment Rights
Provided by Brown & Brown of Louisiana, LLC HIPAA Special Enrollment Rights Group health plans often provide eligible employees with two regular opportunities to elect health coverage an initial enrollment
More informationFlexible Benefits Training What is a Cafeteria Plan? What is a Cafeteria Plan? What is a Cafeteria Plan?
Flexible Benefits Training What is a Cafeteria Plan? What is a Cafeteria Plan? Created by Revenue Act of 1978. A cafeteria plan (flexible spending account) provides one way for an employer to deliver a
More informationERISA Requirements for Employee Welfare Benefit Plans. Presented By: Judy Griffith Kegel Kelin Almy & Lord LLP
ERISA Requirements for Employee Welfare Benefit Plans Presented By: Judy Griffith Kegel Kelin Almy & Lord LLP Judy Griffith Introduction Employee Benefits and ERISA attorney at Kegel Kelin Almy & Lord
More informationHIPAA Special Enrollment Rights
Provided by Clarke & Company Benefits, LLC HIPAA Special Enrollment Rights Group health plans often provide eligible employees with two regular opportunities to elect health coverage an initial enrollment
More informationPPACA Uniform Compliance Summary
Please select the appropriate check box below to indicate which product is amended by this filing. INDIVIDUAL HEALTH BENEFIT PLANS (Complete SECTION A only) SMALL / LARGE GROUP HEALTH BENEFIT PLANS (Complete
More informationKey Elements of Health Care Reform for Employers
Key Elements of Health Care Reform for Employers Change in tax treatment for over-age 2010 dependent coverage Early retiree medical reinsurance Accounting impact of change in Medicare retiree drug subsidy
More informationCompliance Checklist For Group Health Plans
Compliance Checklist For Group Health Plans Page 2 of 47 This Compliance Checklist outlines general federal group health plan requirements, including certain federal mandates, plan reporting requirements,
More informationSection 106, IRC, Contributions by employer to accident and health plans: (a) General rule
By: Bob Butler WASB Associate Executive Director & Staff Counsel bbutler@wasb.org 1-877-705-4422 (phone) 1-608-512-1703 (direct phone) 1-608-257-8386 (fax) A few tax basics. The constructive receipt doctrine.
More informationSection 125: Cafeteria Plan Common Questions
Provided by Brown & Brown of Louisiana, LLC Section 125: Cafeteria Plan Common Questions A Section 125 plan, or a cafeteria plan, allows employers to provide their employees with a choice between cash
More informationPRE-TAX HEALTH ACCOUNTS:
PRE-TAX HEALTH S: A Breakdown SIDE-BY-SIDE COMPARISONS OF 3 HEALTH S PROVIDED BY PRIMEPAY BENEFIT SERVICES FSA HRA HSA FLEXIBLE SPENDING HEALTH REIMBURSEMENT HEALTH SAVINGS PRE-TAX HEALTH S: A BREAKDOWN
More informationFinal Benefit and Payment Parameters Regulations Have Wide Ranging Implications Cost-Sharing Limits
» 3/19/15 2015-03 Regulatory Roundup: Flex Credit/Cash-in-Lieu Potential Impact on Plan Affordability and New Guidance on Cost- Sharing Limits, Reinsurance, Essential Health Benefits, and More Flex Credits
More informationNFIB v. Kathleen Sebelius and its Impact on Employers: Healthcare Reform Revisited
July 5, 2012 NFIB v. Kathleen Sebelius and its Impact on Employers: Healthcare Reform Revisited The Patient Protection and Affordable Care Act (the Affordable Care Act ) imposes new requirements on individuals
More informationHealth Care Reform Overview
Publication date: March 2014 Health Care Reform Overview for Large Group (51+) Plans The following chart provides a breakdown of key Affordable Care Act (ACA) provisions by year for large group plans,
More informationVEHI GENERAL COBRA INFORMATION SUMMARY January 2018 IMPORTANT
VEHI GENERAL COBRA INFORMATION SUMMARY January 2018 IMPORTANT As you know, COBRA continues to be an important part of overall benefit administration. For purposes of continuation coverage, all VEHI group
More informationPlan Document and Summary Plan Description for the EAG, Inc. Employee Welfare Plan
Plan Document and Summary Plan Description for the EAG, Inc. Employee Welfare Plan Your Health Care Benefits Your Health Reimbursement Arrangement ( HRA ) Your Life Insurance and AD&D Benefits Your Disability
More informationIRS Clarifies Adult Child Dependent Coverage and Federal Healthcare Tax Credit for Small Employers
IRS Clarifies Adult Child Dependent Coverage and Federal Healthcare Tax Credit for Small Employers For additional information, please contact your Account Manager or Tony Sorrentino at 402.964.5470 or
More informationDate: April 13, 2009 Code: TECHNICAL LETTER HR/Benefits To: Human Resources Directors Benefits Representatives
Office of the Chancellor 401 Golden Shore, 4 th Floor Long Beach, CA 90802-4210 562-951-4411 E-mail: hradmin@calstate.edu Date: April 13, 2009 Code: TECHNICAL LETTER HR/Benefits 2009-02 To: Human Resources
More informationCAFETERIA PLANS. The Essentials of Plan Design and Regulatory Compliance. Presented By Sandra C. Krauer Director, Client Risk Management Services
CAFETERIA PLANS The Essentials of Plan Design and Regulatory Compliance Richard J. Princinsky & Associates, Inc. designs and manages cost-effective, integrated employee benefit programs with a customer
More informationDOL Health Plan Audit
Employee Benefits Series DOL Health Plan Audit DOCUMENT REQUEST CHECKLIST The following checklist provides a summary of documents that may be requested from employers who sponsor group health plans in
More informationMVP Insurance Agency October 2013 Newsletter - Your Health Care Reform Partner
MVP Insurance October 2013 Newsletter - Your Health Care Reform Partner Are you in compliance with health care reform regulations? We can help you stay on top of health care reform to avoid penalties from
More informationUpdated Summary of Health Care Reform for Employers Preparing for the Future Reissued October 14, 2010, to Include Implementation Guidance
Updated Summary of Health Care Reform for Employers Preparing for the Future Reissued, to Include Implementation Guidance Summary Updated to Include Implementation Guidance Ice Miller originally issued
More information