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July 11, 2011
HRB 36 - Modifications to Claims and Appeals, and External Review
July 7, 2011
IRS Increases Mileage Rate for Medical Expense Reimbursement
Due to the increased cost of gasoline, the IRS revised the optional standard mileage rates for purposes of computing the deductible costs of operating an automobile for medical expense reimbursements, as well as for business and moving expense purposes. Below are the reimbursement rates for the first and second six-month periods in 2011.
Marriage Recognition Updates: New York and Rhode Island
New York: Same-Sex Marriage
June 22, 2011
HRB 35 - Update: Mini-Med Plan Waivers
June 7, 2011
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.
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.
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.
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.
May 12, 2011
Medicare Part D Updates
Change in Medicare Part D Annual Enrollment Period plus New Model Notices of Creditable and Non-Creditable Coverage