Healthcare

Wednesday, 31 August 2016

Can our self-insured plan charge tobacco users more for coverage?

Written by Thomson Reuters

Question: We're concerned about our self-insured plan's compliance with the nondiscrimination rules under the Health Insurance Portability and Accountability Act (HIPAA). Would we be in violation if the plan requires employees who use tobacco to pay more for coverage than employees who don't use tobacco? Answer: No, you wouldn't necessarily be out of compliance — but you must get the details right. As long as the cost difference is structured as part of a wellness program, and the applicable conditions are met, you can charge tobacco users a higher contribution rate to participate in your group health plan without violating HIPAA's nondiscrimination rules...

Published in Healthcare
Wednesday, 31 August 2016

Significant changes proposed for Form 5500

Written by Thomson Reuters

Earlier this year, the Department of Labor (DOL), IRS and Pension Benefit Guaranty Corporation jointly proposed major changes to Form 5500. Employers use this form to file an employee benefit plan’s annual information return with the DOL. According to an agency fact sheet, the proposals are intended to improve employee benefit plan reporting by requiring more detailed information on issues such as group health plan compliance, plan investments and service provider fees. Some of the changes would be specifically for 401(k) retirement plans, but many would affect health plans...

Published in Healthcare
Wednesday, 31 August 2016

It could happen to you: Receiving a Marketplace notice

Written by Thomson Reuters

Even if you haven’t yet received a notice from a Health Insurance Marketplace (often referred to as an “exchange”), it could still happen. The arrival of said document isn’t a cause for panic. But every employer should know whether they need to be prepared to take action. Who distributes them A federal agency called the Center for Consumer Information and Insurance Oversight is charged with administering the Affordable Care Act’s (ACA’s) Employer Notice Program...

Published in Healthcare

New payment models that reward organizations for keeping patients healthy and impose penalties for patient readmissions to hospitals are spurring doctors, hospitals, and delivery systems to reconsider the acquisitions and strategic partnerships that they first tried 20 years ago. Planning ahead for potential strategic partnerships If a physician practice believes that its future lies in a strategic partnership with a hospital or health system, it should begin preparations now. Here are some ways to accomplish that goal:Identify practice leaders and offer them leadership training. Your partner wants to negotiate with responsible individuals and admit them to the leadership team of the integrated organization...

Published in Healthcare
Monday, 01 August 2016

May we impose a new waiting period on a rehired employee?

Written by Thomson Reuters

Question: Our company sponsors a group health plan under which full-time employees are eligible for coverage after a 90-day waiting period. We’re a small business (fewer than 20 employees) and not subject to the Affordable Care Act’s (ACA’s) employer shared-responsibility provisions. Because of business needs, we occasionally rehire employees whose employment was previously terminated. Are we permitted to impose the plan’s waiting period on such rehires?..

Published in Healthcare
Monday, 01 August 2016

Proposed regs address expatriate plans, excepted benefits and more

Written by Thomson Reuters

In June, the Department of Labor, Department of Health and Human Services and IRS jointly issued proposed regulations addressing various provisions of the Affordable Care Act (ACA). In particular, the regs cover expatriate health plans, excepted benefits and the definition of essential health benefits (EHB) for purposes of the prohibition on lifetime and annual dollar limits. The agencies proposed the regulations to apply to plan years beginning on or after January 1, 2017, though reliance is permitted pending the applicability of the final versions. To the extent that the final regs are more restrictive, they’ll be applied without retroactive effect...

Published in Healthcare
Monday, 01 August 2016

Focus on the most common ACA compliance mistakes

Written by Thomson Reuters

Given the complexity of the Affordable Care Act (ACA), it should come as no surprise that many employers occasionally stumble in their compliance efforts. The best way to avoid an IRS audit and potential penalties is by taking a proactive rather than reactive approach. Formalize your approach Among the most heralded best practices in ACA compliance is the creation and adoption of formal policies to guide decision making. Among other topics, important matters to address include: Procedures for classifying employees as full time, part time, seasonal or variable-hour to determine their coverage eligibility (such as your "look-back" measurement process), How you determine whether your plan satisfies the ACA's affordability requirements — including whether you use safe harbor rules and, if so, which ones and for which category of employees, Your method for determining whether an employee who has been rehired after an absence will be counted as a continuing or a new employee, and What health coverage is available to employees out on unpaid leave, and for what period of time...

Published in Healthcare
Tuesday, 05 July 2016

Studying up on the latest EEOC regulations on wellness plans

Written by Thomson Reuters

The Affordable Care Act (ACA) encourages employers to boost participation in wellness programs by offering higher limits on incentives to employees who take part in these initiatives. At the same time, the federal government continues to discourage employers from doling out financial incentives in a discriminatory manner. Some employers do so by making it unduly hard or impossible for certain people to meaningfully participate in a wellness program. To more closely enforce compliance, the Equal Employment Opportunity Commission (EEOC) recently finalized a pair of regulations that take effect on January 1, 2017...

Published in Healthcare
Tuesday, 05 July 2016

Are QMCSOs still available under the Affordable Care Act?

Written by Thomson Reuters

Question: Our company used to occasionally receive a qualified medical child support order (QMCSO). But we haven’t seen one for a few years now. Are they still available under the Affordable Care Act (ACA)? Answer: Yes, QMCSOs are still available...

Published in Healthcare
Tuesday, 05 July 2016

Final HHS regulations extend nondiscrimination rules to many plans

Written by Thomson Reuters

Earlier this year, the Department of Health and Human Services (HHS) finalized regulations implementing the Affordable Care Act’s Section 1557. The provision prohibits discrimination in certain “health programs and activities” on the basis of race, color, national origin, sex, age or disability. And it applies broadly to a wide variety of federally assisted entities, though these final regulations apply only to health programs and activities funded or administered by the HHS. Notably, however, this applicability draws in federal and state Health Insurance Marketplaces — including Small Business Health Options Programs (SHOPs) and the insurers that participate in them...

Published in Healthcare
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