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August 30, 2011
Updated Medicaid/CHIP Premium Assistance Notice Issued
Individuals who are eligible for employer-sponsored group health coverage, but are unable to afford the premium, may be eligible to receive premium assistance from a state’s Medicaid agency or CHIP program. Employers are required to provide premium assistance information to their employees. This can be accomplished by using a model notice provided by the Department of Labor (see Medicaid/CHIP Premium Assistance Notice Issued, Benefit Beat, 3/4/10). The DOL has recently released its revised Medicaid/CHIP notice that can be obtained from its website (click here for 7/31/11 version).
Keeping Medical Information Confidential
What can employers do with medical information, particularly medical information that is protected by the Americans with Disabilities Act (ADA) or the Genetic Information Nondiscrimination Act (GINA), is an open-ended question. The Equal Employment Opportunity Commission (EEOC) is the division of the Department of Labor responsible for administering both the ADA and GINA. The EEOC has recently issued two informal, non-binding Opinion Letters expressing some thoughts on these matters.
Expiration of COBRA Subsidy
The COBRA premium assistance subsidy ended May 31, 2010, and has not been reinstated. Therefore, individuals who were involuntarily terminated after May 31, 2010, do not qualify for the subsidy. However, individuals who qualified for the subsidy on or before May 31, 2010 could continue to pay reduced premiums for the full subsidy period (15 months), as long as they are not eligible for another group health plan or Medicare. For employees who elected the subsidy in May 2010, and had no access to other health coverage since, their 15 months of COBRA premium subsidies expired at the end of August 2011. There may be some additional months of subsidy available in the limited situations in which a qualifying event on or before May 31, 2010, but COBRA did not commence until some date thereafter.
Reminder: Change in Medicare Part D Open Enrollment Period
As mentioned earlier this year (see Medicare Part D Updates, Benefit Beat, May 2011), the health care reform law changed the Medicare Part D annual enrollment period. Beginning this year, the Medicare Part D enrollment period will take place from October 15, 2011 through December 7, 2011. Therefore, all Medicare Part D notices of creditable or non-creditable coverage must be provided prior to October 15, 2011. CMS issued revised model Notices of Creditable and Non-Creditable Coverage to be used on or after April 1, 2011, in both English and Spanish:
August 23, 2011
HRB 39 - Relief for Stand-Alone Health Reimbursement Arrangements
August 18, 2011
HRB 38 - Proposals on Exchanges, Premium Assistance and Uniform Benefit Summary
August 8, 2011
San Francisco HCSO Expenditure Rates for 2012
Covered employers who are subject to San Francisco’s Ordinance are required to make health care expenditures (HCE) to, or on behalf of, their covered employees. These expenditure amounts are adjusted annually, in accordance with the San Francisco Ordinance. Nonprofit entities with fewer than 50 employees, and small employers (those with fewer than 20 employees) are exempt from these provisions.
New York Imposes New Dependent Reporting Requirements on Employers
Presumably, in an effort to augment dependent health coverage, the State of New York has recently passed a law requiring that employers report both for new hires, and on a quarterly basis, the availability of dependent coverage. This applies to employers who have employees who work or reside in New York.
Extension for Self-Reporting of Welfare Benefit Plan Violations
For the past two years, it has been incumbent upon employers sponsoring group health plans, as well as certain other responsible entities, such as insurers or third party administrators, to self-report certain welfare benefit plan violations (see Welfare Benefit Plan Violations: Self-Reporting Required from the November 2009 Benefit Beat). Such violations would include those relating to:
Service Provider and Participant Fee Disclosure Final Regulation Issued
The DOL’s Employee Benefit Security Administration (EBSA) has issued a final rule that provides for an extension of the applicability dates relating to service provider fee disclosure to plan sponsors, and the participant level fee disclosure rules. According to the final rule: