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June 29, 2010

HRB 8 - Early Retiree Reinsurance Program Application Process Opened

June 29, 2010 -- Today, the Department of Health and Human Services officially opened the Early Retiree Reinsurance Program (ERRP) application process, and will begin accepting ERRP applications immediately.  For information relating to ERRP, please refer to prior CBIZ Health Reform Bulletins:Early Retiree Subsidy – Initial Application Date is Approaching and Early Retiree Reinsurance Program.

June 23, 2010

HRB 7 - Patient’s Bill of Rights

June 23, 2010 -- On June 22, 2010, the Departments of Health and Human Services, Labor and Treasury (“Agencies”) issued another round of interim final regulations, implementing certain aspects of the health care reform law.  The regulations, curiously known as the “Patient’s Bill of Rights,” address such matters as the ban on annual and lifetime limits, preexisting condition exclusions, and rescissions, as well as some consumer protections, such as choice of primary care provider and emergency room access.  Following are highlights from these regulations.

June 16, 2010

HRB 6 - Grandfathered Health Plans Rules

June 16, 2010 -- One of President Obama’s health care reform commitments has been, “If you like your health coverage, you can keep it.”  The “grandfathered” health plan rules, contained in the Patient Protection and Affordable Care Act (PPACA), are ostensibly the mechanism for accomplishing this. 

June 11, 2010

HRB 5 - Early Retiree Subsidy – Initial Application Date is Approaching

June 11, 2010 -- As part of the Affordable Care and Patient Protection Act of 2010, an Early Retiree Reinsurance Program has been established. This temporary program, established by way of the health care reform laws, provides reimbursement of certain expenses to plan sponsors of group health plans that provide retiree coverage to early retirees, and their eligible spouses and dependents. While the Department of Health and Human Services set June 1, 2010, as the new effective date of this program, much is still needed to do in order to qualify for this reinsurance subsidy.  It is important to pursue this quickly if you are interested, as only $5 billion of funds are allocated to this program.  More questions still remain at this point, including the extent to which the employer may benefit from receiving a subsidy.  The clear intent of this program is to have employers pass along the benefits to early retirees currently included in their group plan.  The benefits could occur in the form of reduced contributions for coverage, lower deductibles, lower copayments and other forms of subsidies. 

June 7, 2010

IRS’ Compliance Questionnaire: 401(k) Plans

As part of an IRS compliance project, the agency is sending out approximately 1,200 questionnaires to a randomly selected group of 401(k) plan sponsors.  The goals of the questionnaire are to determine any potential compliance issues or plan operational issues, as well as to determine whether any additional education or guidance from the IRS would be beneficial for improving compliance.  The scope of the questionnaire includes the following topics:

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 HRAsBenefit 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.

June 7, 2010

No Change in Cost of Living Adjustments for HSAs

In Rev Proc 2010-22, the IRS released 2011 cost of living adjustments (COLA) for health savings accounts; however, you will note that there are no adjustments for 2011.  A COLA is based on the cost of living index; which has dropped; and thus, there are no increases for 2011.

May 20, 2010

HRB 4 - The Small Business Health Care Tax Credit

May 20, 2010 -- Small businesses and tax-exempt employers that provide health care coverage to their employees under a qualified health care arrangement may now qualify for a special tax credit starting this year.  Included in the recent health care reform legislation passed in March, the credit is designed to encourage small businesses that employ low and moderate income workers to offer and maintain health insurance coverage for their employees.  To qualify for the credit, the employer must have a plan that requires the employer to contribute at least half the cost of participating employees’ health insurance premiums.   On May 17, 2010, the Internal Revenue Service issued Notice 2010-44, providing additional clarification and guidance for employers regarding the Small Business Tax Credit. 

May 10, 2010

HRB 3 - Health Reform’s Coverage for Dependent Children Explained

May 10, 2010 -- The Patient Protection and Affordable Care Act (“PPACA”) provides that if an individual or group health plan (whether insured or self-funded) provides coverage for dependents, a dependent child must be allowed to remain on the plan until he/she reaches his/her 26th birthday.  This provision in the law takes effect on the first day of the first plan year beginning on or after September 23, 2010 (January 1, 2011 for calendar year plans). 

May 5, 2010

HRB 2 - Early Retiree Reinsurance Program

May 5, 2010 -- The Department of Health and Human Services (HHS) has just issued interim final regulations, and a Fact Sheet, relating to the Early Retiree Reinsurance Program.  This temporary program, established by way of the health care reform laws, provides reimbursement of certain expenses to plan sponsors of group health plans that provide retiree coverage to early retirees, and their eligible spouses and dependents.
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