Business Insights, Research & Perspectives

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January 10, 2011

HRB 30 - Limited Relief for Debit Card Purchases of OTC Medications

January 10, 2011 --  As part of the Patient Protection and Affordable Care Act, over-the-counter (OTC) medications, excluding insulin, cannot be reimbursed from medical spending accounts, such as flexible medical spending accounts, health reimbursement arrangements, or health savings accounts, unless a prescription for the OTC medication has been issued.  Medical supplies, such as crutches, band-aids, or blood sugar test kits, can continue to be reimbursed from medical spending accounts, without a prescription.  According to IRS Notice 2010-59, after January 15, 2011, debit cards can no longer be used for the purchase of these items, given the complexity of proving (substantiating) the prescription (see

January 5, 2011

2010 Form M-1 Filing

The DOL has released the 2010 edition of the Form M-1 Filing Packet. If you sponsored a multiple employer welfare arrangement (MEWA) in 2010, make certain that you file the Form M-1 annual report by March 1, 2011 (an automatic 60-day extension to May 3, 2011 can be requested).

January 5, 2011

Extension of Health Coverage Tax Credit Available for Certain Individuals

The Trade Act of 2002 established a premium assistance program to individuals whose jobs are lost due to foreign trade-related agreements, with the purchase of COBRA or other health coverage. The assistance is in the form of a refundable tax credit, equaling 65% of the health premium.  The American Recovery and Reinvestment Act of 2009 (ARRA) increased the tax credit from 65 to 80%, and provided an extension of the credit through December 31, 2010.  Two days before the credit would have expired, Congress passed and President Obama signed the Omnibus Trade Act of 2010 (H.R. 6517) extending the HCTC provision through February 13, 2011.

January 5, 2011

Qualified Transportation Limit Clarified

Shortly after last month’s Benefit Beat was published, President Obama signed the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (Public Law 111-312; enacted 12/17/10).   This law extends the mass transit benefit that was enhanced by the American Recovery and Reinvestment Act of 2009, through 2011. What this means is that the mass transit benefit amount mirrors the qualified parking amount through December 31, 2011. This was followed by an IRS pronouncement (Revenue Procedure 2011-12) which clarifies that the exclusion amount for transportation in a commuter highway vehicle, any transit pass, and parking for 2011 is $230.

December 23, 2010

HRB 29 - Agencies Issue Additional PPACA Clarifications

December 23, 2010 --  In their on-going effort to assist employers in complying with the Patient Protection and Affordable Care Act (PPACA) and other laws, the issuing Agencies (DOL, HHS and IRS) have just provided some sub-regulatory guidance, in the form of Questions and Answers. Of particular note, are the following:

December 23, 2010

HRB 28 - Implementation of Salary-based Discrimination Rules Delayed

December 23, 2010 --  The Patient Protection and Affordable Care Act (PPACA) imposes salary-based discrimination rules on insured health plans (see our CBIZ Bulletin, Salary-based Discrimination Rules Applicable to Fully Insured Group Health Plans). The IRS, with the endorsement by the Departments of Labor and Health and Human Services, has just issued Notice 2011-01, delaying the effective date of these rules. No penalties will be imposed until after implementing regulations are issued.

December 22, 2010

HRB 27 - Additional Guidelines to the Small Business Tax Credit

December 22, 2010 --  As part of the Patient Protection and Affordable Care Act (PPACA), a tax credit is made available to certain small employers who offer qualifying health coverage to their employees (see CBIZ Health Reform Bulletin,

Small Business Health Care Tax Credit). Recently, the IRS released some additional welcome guidance on how this credit is to be implemented, specifically:

  1. New 

December 20, 2010

HRB 26 - Mini-Med Plans: Increased Transparency and Disclosure

December 20, 2010 --  The HHS’ Office of Consumer Information and Insurance Oversight (OCIIO) recently issued two bulletins relating to mini-med plans that seek a waiver from complying with the PPACA’s ban on the imposition of annual or lifetime limits on essential benefits. Our prior Heath Reform Bulletin, Mini-Med Plan Relief from Annual Limit Restriction Offered, issued December 9, 2010, describes the waiver process.

December 16, 2010

HRB 25 - State Tax Treatment of Older-aged Dependent Coverage

December 16, 2010 --  As 2010 comes to a close, issues relating to the taxability of health coverage provided to older-aged dependents must be pondered.  As part of the Patient Protection and Affordable Care Act, health plans that provide coverage for dependents must allow a dependent child to remain on the plan until he/she reaches his/her 26th birthday.

December 7, 2010

Retirement Plan Reminders

In-Plan Roth Conversions

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