New Guidance on Summary of Benefits and Coverage Adds Safe Harbors

Starting on Sept. 23, 2012, health insurers and group health plans will be required to provide the summary of benefits and coverage (SBC) and the uniform glossary to consumers.  On May 11, the Department of Labor’s Employee Benefits Security Administration, together with the Departments of Health and Human Services and the Treasury (the Departments), issued […]

NAHU Hosts Webinar on Exchanges

On May 10, NAHU conducted a one-hour webinar on health insurance exchanges.  It was an exceptionally thorough overview of the topic, and I would encourage folks to listen/view it.  The link to the Professional Development page of NAHU’s site (the webinar is the first item under the NAHU Webcasts heading): http://www.nahu.org/education/programs/webcasts.cfm?ibcToken=a0a490fb-9052-4c36-bd08-d7da54f8f2ef. Just a couple of […]

COMPLIANCE ALERT!! – IRS PROPOSES METHODS FOR VALUING EMPLOYER HEALTH COVERAGE

The IRS has just issued three notices concerning key aspects of the 2010 Affordable Care Act (ACA).   Notice 2012-31 proposes three different methods by which sponsors of self-funded health plans could value the coverage they provide to plan participants and their dependents.   Notice 2012-32 and Notice 2012-33 then solicit comments on two related employer reporting […]

IRS Proposes Regulations on Fees to Fund Patient-Centered Outcomes Research

The IRS has issued proposed regulations regarding the fees imposed by health care reform on health insurers and on sponsors of self-insured health plans to support clinical effectiveness research by the new Patient-Centered Outcomes Research Institute (sometimes referred to as CER or PCOR fees). The fees apply only to policy or plan years ending after […]

Revised Audit Guidelines

Recently, the Internal Revenue Service (IRS) published Revised Audit Guidelines for use by IRS auditors in examining group health plans for COBRA compliance.  The revised Guidelines incorporate changes to account for laws that have affected COBRA since the previous guidelines were developed, such as the Health Insurance Portability and Accountability Act (HIPAA) and the Family […]

State Exchange Regulations Issued

On March 12, the federal Department of Health and Human Services (HHS) released a revised version of the federal rules regarding the “Establishment of Exchanges and Qualified Health Plans and Exchange Standards for Employers.” Parts of the 644-page regulation have been issued as a final rule, meaning that they will have the full force of […]

Agencies Issue Guidance on Waiting Periods

Under the ACA, effective for plan years beginning on or after January 1, 2014, a group health plan may not have a waiting period that exceeds 90 days.  The ACA’s statutory language raised many questions regarding how this 90-day limit on waiting periods should be measured.  Notice 2012-17 continues to leave many of those questions […]

AGENCIES ISSUE GUIDANCE ON AUTOMATIC ENROLLMENT

The ACA provision on automatic enrollment requires certain large employers (those with more than 200 full-time employees) to automatically enroll new full-time employees in one of the employer’s health benefit plans (subject to any legally permissible waiting period), and to continue the enrollment of current employees in a health benefit plan.  It further requires notice […]

Milliman Study Highlights the Impact of Medical Loss Ratio Rules on HSAs

A new report by Milliman Inc. says that high-deductible health plans, including those with health savings accounts (HSAs), will likely be more adversely impacted by the medical loss ratio requirements under PPACA than other types of comprehensive medical plans.  Consumers who rely on HSA-qualified plans to finance their health care may experience greater costs in […]

Agencies Finalize Guidance On Summary Of Benefits And Coverage

As explained in our August 2011 article, the health care reforms enacted in March of 2010 will require employer health plans to provide a uniform “summary of benefits and coverage” (SBC) to all plan participants and beneficiaries.  The agencies charged with implementing this requirement have now finalized the regulations they proposed in August of 2011.  […]

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