Healthcare

Three federal agencies have proposed changes that could bring significant changes to Health Reimbursement Arrangements (HRAs). The IRS, Department of Labor (DOL) and Department of Health and Human Services (HHS) jointly proposed the regulations in response to President Trump’s executive order directing the agencies to consider regulations or guidance that would expand the availability and permitted use of HRAs. Let’s look at some highlights. HRAs funding individual insurance The proposed regulations would allow HRAs to be integrated with, and to reimburse premiums for, individual health insurance coverage if certain conditions are met...

The pace of health care cost inflation has remained moderate over the past year, and employers are trying to keep it that way. Rather than continuing to ask employees to shoulder more of the burden, however, many are aiming at longer-term changes in employee behavior, such as fostering a “culture of health” within their organizations. These insights come from two newly issued reports from a pair of large benefits consulting and insurance brokerage firms, based on surveys conducted earlier this year. Looked at in total, the data indicates that employers are looking less at immediate cost-cutting measures and more at “future-focused” plan features...

Question: Our company, an applicable large employer (ALE) under the Affordable Care Act, sponsors a self-insured health plan. As an ALE, how should we report coverage of family members who elect COBRA separately from the departing employees? Answer: An employer that sponsors a self-insured group health plan is obligated under Internal Revenue Code Section 6055 to report coverage information for all enrollees in the health plan, including nonemployees (such as COBRA beneficiaries). COBRA-qualified beneficiaries may include the spouse (or former spouse) and dependents of a current or former employee...

The IRS has released draft Forms 1094/1095-B (B Forms) and Forms 1094/1095-C (C Forms), and related instructions, for the 2018 tax year. If your organization is considered an applicable large employer (ALE) under the Affordable Care Act, it’s important to stay up to speed on the details. B vs. C As you may recall, the B Forms are filed by minimum essential coverage providers (mostly insurers and government-sponsored programs, but also some self-insuring employers and others) to report coverage information in accordance with Internal Revenue Code (IRC) Section 6055...

Coupling a high-deductible health plan (HDHP) with a Health Savings Account (HSA) has been a popular approach for many employers in the wake of the Affordable Care Act. Approximately 20 million Americans are enrolled in plans following the HDHP+HSA model, according to various estimates. But recent studies show that its growth appears to be tapering off somewhat, even as efforts are underway in Congress to ramp it up again. Cadillac tax The slow growth is a bit of a surprise...

The Department of Labor, Department of Health and Human Services, and IRS jointly finalized regulations in August that extend the permissible duration of short-term, limited-duration health insurance. This action follows President Trump’s executive order directing the agencies to consider regulations or guidance that would allow such insurance to cover longer periods and to be renewed by the consumer. The regs, which finalize previously proposed rules with some modifications, were scheduled to take effect 60 days after publication in the Federal Register. Let’s look at some highlights...

Do you think you’ve tried every strategy under the sun to keep your health plan costs under control without sacrificing quality of care, but are still struggling? Consider direct contracting. It’s not new, and it’s not only about saving money. Simple in theory, but not always in practice, direct contracting has drawn attention both from employers and health providers...

This past June, the IRS’s Office of Chief Counsel released an information letter on employer shared responsibility under Internal Revenue Code Section 4980H as set forth under the Affordable Care Act. The letter serves as a response to an inquiry from a legislator on behalf of a constituent who owns a small business. The constituent’s company is subject to federal prevailing wage laws under the Service Contract Act (SCA) and has grown to become an applicable large employer (ALE) under the Affordable Care Act for purposes of employer shared responsibility. ALEs may be subject to penalties under Sec...

Depending on who’s doing the talking, the recent loosening of requirements for forming association health plans (AHPs) will either dramatically improve or worsen the health care benefits landscape. Proponents say it will greatly expand coverage for employees of smaller employers. Meanwhile, detractors contend it will lead to widespread fraud and inferior benefits for those same employees. The truth may lie somewhere in between...

Question: We’ve been asked whether our Health Flexible Spending Account (FSA) can reimburse medical expenses incurred by an employee’s nonspouse domestic partner. Are these expenses eligible for reimbursement? Answer: It depends. Under Internal Revenue Code Section 105(b), only the following individuals’ medical expenses are eligible for tax-free reimbursement from a Health FSA: The employee, The employee’s spouse, The employee’s child who’s under age 27 as of the end of the employee’s taxable year, and An individual who’s the employee’s tax dependent for health coverage purposes...