Healthcare

Monday, 01 June 2015

Must self-insured plans provide essential health benefits?

Written by Thomson Reuters

Question: We understand that the Affordable Care Act (ACA) requires some health care plans to cover certain "essential health benefits." Does that include our self-insured plan? Answer: No, self-insured plans aren't required to include essential health benefits. However, as discussed below, they're prohibited from imposing annual or lifetime dollar limits on any essential health benefits they do offer...

Published in Healthcare
Wednesday, 29 April 2015

Does the ACA require large employers to offer spousal coverage?

Written by Thomson Reuters

Question: We’re a large employer with thousands of employees. As a way of reducing our overall benefit costs, we offer only employees and their dependent children coverage under our company’s group health plan. We don’t extend coverage to an employee’s spouse. Would spousal exclusion subject us to penalties under the Affordable Care Act’s employer shared responsibility requirements?..

Published in Healthcare
Wednesday, 29 April 2015

Applying the annual cost-sharing limit to family HDHP coverage

Written by Thomson Reuters

In the preamble to the "Final Notice of Benefit and Payment Parameters for 2016" issued in April, the Department of Health and Human Services (HHS) established that the cost-sharing limit for self-only coverage should apply to all covered individuals — whether or not they're covered by a self-only plan. More recently, the HHS posted a FAQ explaining how the annual cost-sharing limit under the Affordable Care Act (ACA) will affect high-deductible health plan (HDHP) coverage. The new FAQ explains the agency's position by applying it to a hypothetical HDHP with a $10,000 family deductible. Deductible approaches The FAQ notes that, under the rules for Health Savings Accounts (HSAs), HDHP family coverage cannot provide any benefits until covered expenses (other than for preventive care) exceed the minimum annual deductible for family coverage...

Published in Healthcare
Wednesday, 29 April 2015

“Cadillac tax” sparks concerns as imposition date nears

Written by Thomson Reuters

To many employers, insurers and plan administrators, 2018 seems right around the corner. That’s when the Affordable Care Act’s (ACA’s) “Cadillac tax” provision takes effect. And what felt like a distant prospect when the ACA was enacted five years ago looms large today — particularly given its prospect of imposing a heavy 40% tax burden on the value of health benefits exceeding specified limits. As originally perceived and characterized, the Cadillac tax would impact only particularly generous plans...

Published in Healthcare
Monday, 30 March 2015

IRS Notice 2015-17: Limited relief for payment plan violations

Written by Thomson Reuters

The IRS has long held the position that, subject to narrow exceptions, an employer violates the Affordable Care Act’s (ACA’s) annual dollar limit and preventive services mandates by reimbursing or paying employee premiums for individual health insurance. This is because such “employer payment plans” are treated as separate group health plans that impose prohibited limits but cannot be integrated with the individual policy coverage. After articulating this position in Notice 2013-54, the IRS has repeated it in Q&As, FAQs and information letters — emphasizing the severe excise tax consequences of violating these mandates. Now the agency has issued Notice 2015-17, also written in Q&A format, which covers some new ground by providing relief in limited circumstances...

Published in Healthcare
Monday, 30 March 2015

Can our plan require preauthorization for OB/GYN services?

Written by Thomson Reuters

Question: Our company’s self-insured group health plan requires preauthorization for certain obstetrical and gynecological (OB/GYN) services. Is this plan design permissible under the patient protection provisions of the Affordable Care Act (ACA)? Answer: Yes, so long as the preauthorization requirement applies to specific OB/GYN services and doesn’t restrict access to any providers specializing in obstetrics or gynecology. The ACA’s patient protections require a choice of health care professionals, including OB/GYN providers...

Published in Healthcare
Monday, 30 March 2015

New HHS rules for 2016 tighten “minimum value” standard

Written by Thomson Reuters

An apparently unintended loophole in the Affordable Care Act (ACA) has been closed. Under previous rules, large employers (as defined under the act) would have been able to satisfy the ACA’s “minimum value” test for health care coverage by offering streamlined plans that didn’t cover inpatient hospital visits. “Final Notice of Benefit and Payment Parameters for 2016,” issued by the Department of Health and Human Services (HHS), has announced that this is no longer allowed, though employers that had signed contracts for 2015 plans by Nov. 4, 2014, are permitted to keep those plans in place this year...

Published in Healthcare
Monday, 02 March 2015

Must our plan cover the pregnancy expenses of employees’ children?

Written by Thomson Reuters

Question: Our company’s major medical plan covers the pregnancy-related expenses of employees and their spouses. But, in light of the many changes to health care law recently, is our plan now also required to cover pregnancy-related expenses of employees’ children who are enrolled as dependents? Answer: The Affordable Care Act (ACA) does indeed require group health plans that provide dependent coverage for participants’ children to make such coverage available until a child turns age 26. But plans don’t necessarily have to cover the pregnancy-related expenses of those children...

Published in Healthcare

Earlier this year, the Department of Labor (DOL), IRS and Department of Health and Human Services (HHS) jointly issued proposed regulations that may place another item in the “excepted benefit” category. Namely, under the proposal, employers can in certain circumstances offer limited health coverage designed to wrap around individual health insurance. Thereafter, such “wraparound” coverage would qualify as an excepted benefit — in other words, one exempt from certain group health plan mandates under the Health Insurance Portability and Accountability Act and the Affordable Care Act (ACA). The concept of limited wraparound coverage as an excepted benefit was originally contained in proposed regulations published in December 2013...

Published in Healthcare
Monday, 02 March 2015

Survey says: Plan designs reflect market, regulatory forces

Written by Thomson Reuters

As is the case for many employers, the design of your health care plan is likely based on a mixture of benefits philosophy, legal requirements, financial parameters and workforce demographics. Yet you shouldn’t make plan design decisions in a vacuum. Knowing what other employers are doing and discovering new opportunities to build greater plan efficiency are essential. A comprehensive annual survey by United Benefit Advisors (UBA), a consortium of benefits consulting and brokerage companies, offers a good look at what’s going on...

Published in Healthcare
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