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June 16, 2010
HRB 6 - Grandfathered Health Plans Rules
June 11, 2010
HRB 5 - Early Retiree Subsidy – Initial Application Date is Approaching
June 7, 2010
IRS’ Compliance Questionnaire: 401(k) Plans
As part of an IRS compliance project, the agency is sending out approximately 1,200 questionnaires to a randomly selected group of 401(k) plan sponsors. The goals of the questionnaire are to determine any potential compliance issues or plan operational issues, as well as to determine whether any additional education or guidance from the IRS would be beneficial for improving compliance. The scope of the questionnaire includes the following topics:
No Change in Cost of Living Adjustments for HSAs
In Rev Proc 2010-22, the IRS released 2011 cost of living adjustments (COLA) for health savings accounts; however, you will note that there are no adjustments for 2011. A COLA is based on the cost of living index; which has dropped; and thus, there are no increases for 2011.
Updated Information: Mandatory Medicare Reporting for HRAs
In an effort to ensure that the Medicare Secondary Payor rules are properly administered, the Centers for Medicare and Medicaid Services (CMS) imposed a mandatory reporting requirement on insurers, third party administrators, and plan administrators of self-funded, self-administered health plans, collectively referred to as “Responsible Reporting Entities” (RREs). The type of information to be reported relates to Medicare beneficiaries who have group health plan coverage. While this reporting rule became effective January 1, 2009, it is only recently become effective for health reimbursement arrangements (HRAs)(see CMS Clarifies Medicare Mandatory Reporting Requirement for HRAs, Benefit Beat, August 2009). CMS recently issued an Alert updating information relating to the mandatory Medicare reporting for HRAs. Registration for HRA-only RREs began May 1, 2010 and must be completed by June 30, 2010. The data submission testing period for HRAs will begin July 1, 2010; production reporting of HRA coverage information will begin October 1, 2010.
May 20, 2010
HRB 4 - The Small Business Health Care Tax Credit
May 10, 2010
HRB 3 - Health Reform’s Coverage for Dependent Children Explained
May 5, 2010
HRB 2 - Early Retiree Reinsurance Program
May 4, 2010
TRICARE Secondary Payor Rules: Final Regulations Issued
The Department of Defense issued final regulations relating to TRICARE secondary payor rules (seeEmployer Coverage? TRICARE? Beware! from the April ’08 Benefit Beat, andNew TRICARE Provisions Affect Group Health Plans from Nov. ’06 Benefit Beat). In summary, these rules are similar to the Medicare secondary payor rules. If an individual entitled to TRICARE is actively working, the employer cannot do anything to incent the individual to choose TRICARE over the employer’s sponsored health plan. In other words, the employer cannot, in any way, incent the employee to choose TRICARE, rather than the employer’s plan. This choice strictly rests with the individual. Furthermore, an employer is prohibited from paying for a TRICARE supplemental plan.
COBRA Subsidy Extension: Revised Model COBRA Notices and Other Updated Information
In its ongoing effort to assist with COBRA subsidy compliance, the Department of Labor has just issued several documents that have been updated to reflect the extension of the COBRA subsidy eligibly period through May 31, 2010 (seeCOBRA Subsidy Extended….Again! from the April ’10 Benefit Beat). Included among these documents are new model notices, discussed below, Application for Expedited Review of Denial of COBRA Premium Reduction, Fact Sheet, and Frequently Asked Questions.