As we process the results of Tuesday’s national elections, we begin to consider the impact on the employee benefits industry for 2017 and beyond.
Earlier this year, the IRS provided much needed guidance regarding COBRA’s application to Health FSA plans with the carryover feature in IRS Notice 2015-87. The guidance largely confirmed our understanding of the issues.
You are invited to participate in our next client webinar on Tuesday, June 28 at 11:00 am. As the smoke continues to clear...
Health Savings Accounts (HSAs) continue to be a popular tax-favored investment and medical expense reimbursement component of employee benefits packages. Here are the basics to help you with tax time.
How is HSA eligibility impacted by an individual's 65th birthday and Medicare eligibility? There is often confusion around this topic and whether eligibility to make or receive Health Savings Account ("HSA") contributions ends upon an individual's 65th birthday.
On October 21, the IRS released Revenue Procedure 2015-53 providing certain cost of living and indexing information for 2016. In the Revenue Procedure, the IRS released the Health FSA max for 2016 plans, which will remain unchanged from 2015 - $2,550.
The IRS has announced the following maximums and limits for 2016 Welfare Benefit Plans. Notably, the Health FSA maximum, HSA minimum annual deductibles, and annual single HSA contribution limit remain unchanged. The annual family HSA contribution limit increases by $100.
The ACA's new IRS reporting requirements for employers continue to be the hottest new compliance topic of 2015. To confirm, these requirements apply to employers that had 50 or more full-time employees, including full-time equivalents, during 2014. Employers subject to the requirements will have to provide Form 1095-C by 2/1/16 to all employees that were full-time during 2015, and provide Form 1094-C to the IRS, along with copies of all Forms 1095-C, by 2/29/16 (3/31/16 if electronically submitted).
A. It is becoming more common for physicians to charge "hold the spot" fees (retainer fees, access fees) or require patients to pay for MD/VIP programs in order to gain access to care or preferred services from the physician (favorable appointment booking, shorter waiting times).
You are invited to participate in our monthly client webinar on Tuesday, October 20 at 11:00 am. This session will provide several updates relevant to the current enrollment season, including...
Now is the time of year that Flexible Spending Account ("FSA") participants begin thinking about spending down remaining FSA funds to avoid losing contributions during the transition to the next plan year.
Even amid the continued frenzy of the Affordable Care Act, many questions that we receive relate to long-standing benefits rules, such as ERISA requirements for SPDs. In response to the current need and demand for Wrap SPDs for health and welfare benefit plans, we have designed an efficient and economical solution for employers.
As the summer comes to a close and the 4th Quarter of 2015 approaches, the end of the plan year for many benefit plans is not far away. Often, a new plan year involves plan design changes or compliance changes that should be detailed in the plan legal documents and communicated to participants.
You are invited to participate in our monthly client webinar on Tuesday, September 15 at 11:00 am. This short session (30 minutes) will provide an update on federal ERISA requirements for group health and welfare plans, including...
You are invited to participate in our monthly client webinar on Tuesday, August 18 at 11:00 am. This session will focus on ACA compliance for employers of various sizes and will include...
Last month, the Supreme Court announced its decision in Obergefell v. Hodges, effectively preventing any state from prohibiting same-sex marriage and failing to recognize the benefits of marriage for same-sex spouses. For benefits purposes, Obergefell builds on the previous decision in U.S. v. Windsor and agency guidance following that decision.
The long-awaited Supreme Court decision is final. Much like June 2012, the ACA has survived another significant challenge, and it is once again full steam ahead for compliance with the law. I was not surprised by the result, but it was striking to see the 6-3 margin and the strength of position expressed by the Chief Justice in his majority opinion.
If you or your clients are self-administering COBRA, why not help alleviate the burden of self-administration? Most groups find self-administering COBRA to be too complicated and time-consuming. In addition, the risks of COBRA non-compliance are simply too great to take for granted.
You are invited to participate in our monthly client webinar on Tuesday, June 16 at 11:00 am. This session (45 minutes) will provide an update on federal COBRA requirements for group health plans.
As we wrote in a recent post, a topic of significant importance in the benefits world is compliance with Department of Labor (ERISA) rules regarding annual Form 5500 reporting for employers.
You are invited to participate in our monthly client webinar on Tuesday, May 19 at 11:00am EST. This short session (30 minutes) will provide an update on ERISA Form 5500 reporting requirements for health and welfare plans
I hope that 2015 is going well for you and your organization. On the ACA front, new activity has been relatively "calm" since a busy February. The only significant development in the last two months was the EEOC's April 16 release of proposed regs relating to wellness programs and compliance with the Americans with Disabilities Act.
An often overlooked compliance topic is ERISA's main reporting requirement - Form 5500 filing. Form 5500 filings are generally required for all health and welfare benefits subject to ERISA, although there is a broad exemption for small, fully insured or unfunded plans.
You are invited to participate in our monthly client webinar on Tuesday, April 21 at 11:00 am EST. This session will focus on ACA compliance for employers of various sizes and will include:
Each year, we produce a Benefits Compliance Checklist for employers. This checklist includes key compliance items for health and welfare plans, including issues related to the Affordable Care Act, ERISA, COBRA, HIPAA, and other IRS benefit plan rules.
One dynamic of the complex era of the Affordable Care Act ("ACA") is that many longstanding, common plan design approaches are analyzed with more scrutiny than before. A recent example involves the use of “waiver credits,” the concept whereby an employer offers an incentive to an employee in order for the employee to waive participation in the group health insurance plan on behalf of himself/herself, or on behalf of a spouse or dependent(s).
As part of our Form 5500 and ERISA work, we are receiving a high volume of questions right now regarding Wraparound Summary Plan Descriptions (“Wrap SPDs”). To confirm, the federal rules in this area – specifically, the ERISA disclosure regulations – have not changed. However, there is of course an additional focus on all benefits compliance issues, including SPD compliance, as part of the legal landscape in light of the Affordable Care Act.
The Affordable Care Act introduced Summaries of Benefits and Coverage (“SBCs”) in 2012 as a new participant disclosure requirement for all group health plans. Although there has been no significant change in the legal requirements for SBCs in the two-plus years they have been in effect, 2014 was technically the end of the "non-enforcement period" by the federal Department of Health and Human Services that oversees ACA compliance, including SBCs.