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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.
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.
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.
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.
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.
February 1, 2007
Health Care on the Front Burner
Health care reform is hot, both on the Federal and State agendas. Whether anything substantial comes out of these simmering pots, remains to be seen.
More PPA Guidance
The IRS recently issued Notice 2007-7. This guidance addresses a potpourri of Pension Protection Act of 2006 (PPA) matters. The majority of the Notice relates to distribution issues, and also includes some guidance on the vesting requirements of defined contribution plans. Following is a brief summary of the guidance.
January 4, 2007
Substantiation of Medical Expenses via Debit Cards
Transition relief has been provided in IRS Notice 2007-2 relating to substantiation of employer-provided medical expenses made through debit cards that are used in conjunction with flexible spending accounts or health reimbursement arrangements. Certain items purchased with a debit card may not be identified as qualifying medical expenses under a plan if the vendor or entity does not utilize a merchant category code (MCC) system. Thus, this guidance provides some relief to supermarkets, grocery stores, discount stores, and wholesale clubs that do not have such system in place. The Notice requires these entities to implement a MCC system by January 1, 2008.
DOL Offers Guidance on Benefit Statement Distribution
The Pension Protection Act (PPA) requires that plans provide benefit statements on a more regular basis than previously required (see Notice Requirements from the September, 2006 edition of the Benefit Beat). Specifically, defined contribution plans must provide benefit statements quarterly, as long as the plan allows individual direction. Defined contribution plans that do not allow individual direction must provide benefit statements annually. Defined benefit plans must provide benefit statements every three years, unless the plan elects to comply with an alternative notice requirement.
Group Health Plan Compliance Audit
The Department of Labor is making an effort to ensure that all group health plans subject to ERISA are complying with its requirements, specifically Title 7 of ERISA. This section of ERISA includes provisions relating to the HIPAA portability rules, the Mental Health Parity Act, the Newborns’ and Mothers’ Health Protection Act, and the Women’s Health and Cancer Rights Act.