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June 22, 2011
HRB 35 - Update: Mini-Med Plan Waivers
June 7, 2011
Accountings for PHI Disclosure: Rules Proposed
HHS’ Office of Civil Rights has recently proposed rules relating to accounting of disclosures. The HIPAA law, as modified by the Health Information Technology for Economic and Clinical Health Act (HITECH), requires certain accounting of disclosures of protected health information (PHI) maintained in a designated record set. These rules propose to clarify the types of accounting that are required. Of particular note, the proposal would limit the accounting to the past 3 years.
Health Savings Accounts: 2012 Cost of Living Adjustments
In Rev Proc 2011-32, the IRS released the 2012 cost of living adjustments (COLA) for health savings accounts. Note, the statutory high deductible health plan (HDHP) minimum deductibles remain unchanged from the 2011 limits. The HDHP out-of pocket limits, and the statutory HSA contribution amounts, have increased slightly.
Medicare Part D Notices – Corrected Links
It’s come to our attention that the links to the model Medicare Part D disclosure notices contained in last month’s Benefit Beat article, Medicare Part D Updates, were changed following release of our publication. We‘ve since revised the links contained in this article.
Plan….Summary Plan Description…Which One Governs?
The U.S. Supreme Court has recently rendered an important opinion relating to the role of a summary plan description (SPD). In CIGNA Corp. v. Amara, 2011 WL 1832824 (U.S. 2011), the Supreme Court ruled that the SPD is not part of the plan document. Of particular note, the terms of the SPD that may be in conflict with the plan document, cannot, in effect, amend the terms of the plan. In other words, the terms of the plan govern. This is a departure from some lower court decisions.
Fee Disclosure Applicability Date Modification Proposed
In July, 2010 and October, 2010, respectively, the DOL issued service provider and participant level fee disclosure rules. The Department indicated, informally, that it was considering delaying the applicability date of these regulations in order to give service providers and plan administrators time to comply with the regulations.
May 12, 2011
Revised National Medical Child Support Notice Issued
On occasion, an employer may receive a court order directing the employer and/or plan administrator to enroll an employee’s child(ren) listed in the Order in one or more of its benefit programs, including medical, dental, vision, prescription drug, mental health and other benefit programs. An Order can be received directly from a Court, or by way of a National Medical Support Notice (NMSN) form issued by a State Child Support Agency authorized to enforce medical child support orders.
Medicare Part D Updates
Change in Medicare Part D Annual Enrollment Period plus New Model Notices of Creditable and Non-Creditable Coverage
Update: Wellness Program – ADA Class Action Case
In the April Benefit Beat, a class action lawsuit (Bradley Seff v. Broward County) was mentioned relating to an employer offering financial incentives for participating in a group wellness program. This case addresses the applicability of the Americans with Disabilities Act (ADA) to wellness programs. Specifically, a group of employees challenged the employer’s imposition of a wellness program that requires completion of a health risk assessment (HRA). Failure to complete the HRA would result in a financial penalty. The complainant alleged that this was a violation of the ADA because it impermissibly requested medical information. Generally, the ADA permits the collection of medical information as long as it is voluntary. The “voluntary” nature of the medical information collection was in question.
May 11, 2011
The Outlook for Major Tax Reform: What You Need to Know