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Business Insights, Research & Perspectives

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June 5, 2007

2008 HSA Cost-of-Living Adjustments

In Rev Proc 2007-36, the IRS released 2008 cost of living adjustments for health savings accounts.  Following are annual deductible amounts for a high deductible health plan (HDHP) used in conjunction with a health savings account (HSA), and limits for out-of-pocket expenses and contributions for both 2007 and 2008.

June 5, 2007

Massachusetts Employers: A New Cafeteria Plan Requirement

As part of the Commonwealth of Massachusetts’ effort to provide universal health coverage to all residents, the State is requiring employers to offer its employees an IRC Section 125 (cafeteria) plan, effective July 1, 2007.  This rule applies to all employers employing 11 or more full-time equivalent employees in the Commonwealth.  It applies to employers whether they offer insured health plans, self-funded health plans, or no health insurance plan at all.  Failure to comply with the cafeteria plan requirement may cause the employer to be subject to the Free Rider Surcharge.

May 3, 2007

Rash of Regulations Issued

Last month, three sets of regulations relating to retirement and deferred compensation were issued. 

May 3, 2007

Medicare Part D – 2008 Benefit Limits

The Centers for Medicare and Medicaid Services have released the 2008 cost of living adjustments for Medicare Part D prescription drug benefits.  Following are select  modified limits relating to the standard drug benefit and the retiree drug subsidy.

May 2, 2007

Employers Beware: Comply with Plan Terms

A recent court decision boldly underscores the importance of accurate plan administration, specifically as it relates to eligibility.  In Carolina Care Plan, Inc. v. Auddie Brown Auto Sales of Florence, Inc., 2007 U.S.Dist. LEXIS 24962 (D.N.C. 2007)], the HMO sued the employer for over $650,000 worth of claims reimbursed to an individual who was no longer eligible for the plan. 

April 2, 2007

The National Provider Identifier

One of the components of the HIPAA Administrative simplification law is the establishment of a national provider identification number (NPI).  The intent of this law is to simplify health plan processes, by ensuring that health care providers who engage in electronic transactions will use one identifying number for all of the various health plans with which they engage.  The NPI is similar to a Social Security Number that is used to identify the provider for all purposes. 

April 2, 2007

New Medicare Part D Disclosure Notices

The Centers for Medicare and Medicaid Services (CMS) have issued new model notices of creditable and non-creditable coverage, as well as a personalized disclosure notice, to be used beginning on or after February 15, 2007. Although the substance of these notices is similar to prior versions, the language in the new notices should be used.  In addition, all three forms are now available in both English and Spanish.  

March 1, 2007

Investment Advice Guidance

The Department of Labor (DOL) has issued Field Assistance Bulletin (FAB) 2007-1 relating to the new investment advice provisions of the Pension Protection Act of 2006 (“PPA”).  A FAB provides guidance to the DOL’s field offices about how to administer provisions of the law. 

March 1, 2007

Small Health Plans: Triennial HIPAA Privacy Notice Obligation

Covered entities, including small group health plans (those with fewer than $5 million in receipts), that became subject to the HIPAA Privacy Rules by April 14, 2004, are fast approaching the third anniversary of HIPAA privacy applicability.  This means that it is time to distribute a reminder notice to affected individuals regarding their right to obtain the covered entity’s Notice of Privacy Practices. 

March 1, 2007

Qualified HSA Rollovers

The first piece of guidance relating to qualified distributions from a flexible medical spending account (FSA) or a health reimbursement arrangement (HRA) to a health savings account (HSA) has been issued, in the Form of IRS Notice 2007-22.  The Tax Relief and Health Care Act of 2006 (TRHCA), signed into law in December, 2006, authorized a one-time rollover from an FSA or an HRA, to an HSA. 

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