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June 7, 2010
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
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.
Medicare Part D – 2011 Benefit Limits
The Centers for Medicare and Medicaid Services have released the 2011 cost of living adjustments for Medicare Part D prescription drug benefits. The following are selected modified limits relating to the standard drug benefit and the retiree drug subsidy.
A Confidentiality Reminder
It is of upmost importance to ensure the protection of an individual’s medical information. Several laws address the need to ensure this confidentiality. HIPAA, for example, addresses protected health information derived from covered entities. The Rehabilitation Act, the Americans with Disabilities Act (ADA), as well as the Family and Medical Leave Act, also require that medical information be handled with the upmost care. This issue was highlighted in a recent informal Letter issued by the Equal Employment Opportunity Commission. The Letter specifically relates to the Rehabilitation Act, but is equally applicable for ADA purposes.
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.
April 28, 2010
HRB 1 - IRS Guidance: Tax-Favored Status of Dependent Coverage
April 16, 2010
COBRA Subsidy Extended….Again!
The COBRA subsidy law has been temporarily extended, once again (H.R. 4851, signed by President Obama on April 15, 2010). This is the law that allows individuals involuntarily terminated from employment to pay 35% of the COBRA premium for up to 15 months.