by admin | May 1, 2018 | Benefit Management, Group Benefit Plans, HSA/HRA, IRS
Friday, April 27, the Internal Revenue Service (IRS) announced that the 2018 annual contribution limit to Health Savings Accounts (HSAs) for persons with family coverage under a qualifying High Deductible Health Plan (HDHP) is restored to $6,900. The single-coverage limit of $3,450 is not affected.
This is the final word on what has been an unusual back-and-forth saga. The 2018 family limit of $6,900 had been announced in May 2017. Following passage of the Tax Cuts and Jobs Act in December 2017, however, the IRS was required to modify the methodology used in determining annual inflation-adjusted benefit limits. On March 5, 2018, the IRS announced the 2018 family limit was reduced by $50, retroactively, from $6,900 to $6,850. Since the 2018 tax year was already in progress, this small change was going to require HSA trustees and recordkeepers to implement not-so-small fixes to their systems. The IRS has listened to appeals from the industry, and now is providing relief by reinstating the original 2018 family limit of $6,900.
Employers that offer HSAs to their workers will receive information from their HSA administrator or trustee regarding any updates needed in their payroll files, systems, and employee communications. Note that some administrators had held off making changes after the IRS announcement in March, with the hopes that the IRS would change its position and restore the original limit. So employers will need to consider their specific case with their administrator to determine what steps are needed now.
HSA Summary
An HSA is a tax-exempt savings account employees can use to pay for qualified health expenses. To be eligible to contribute to an HSA, an employee:
- Must be covered by a qualified high deductible health plan (HDHP);
- Must not have any disqualifying health coverage (called “impermissible non-HDHP coverage”);
- Must not be enrolled in Medicare; and
- May not be claimed as a dependent on someone else’s tax return.
HSA 2018 Limits
Limits apply to HSAs based on whether an individual has self-only or family coverage under the qualifying HDHP.
2018 HSA contribution limit:
- Single: $3,450
- Family: $6,900
- Catch-up contributions for those age 55 and older remains at $1,000
2018 HDHP minimum deductible (not applicable to preventive services):
- Single: $1,350
- Family: $2,700
2018 HDHP maximum out-of-pocket limit:
- Single: $6,650
- Family: $13,300*
*If the HDHP is a nongrandfathered plan, a per-person limit of $7,350 also will apply due to the ACA’s cost-sharing provision for essential health benefits.
Originally posted on thinkHR.com
by admin | Apr 27, 2018 | Benefit Management, Compliance
“Here’s an update on EEO-1 reporting by Cara Crotty, partner with leading national labor and employment law firm (and ThinkHR strategic employment law partner) Constangy, Brooks, Smith & Prophete, LLP.”
The new deadline is June 1, but only for this year.
The Equal Employment Opportunity Commission
announced that it has extended the deadline to submit 2017 EEO-1 report data. The deadline, which was March 31, 2018, will now be June 1, 2018. Although the EEOC provided no explanation, anecdotal reports indicate that the agency was slow to respond to requests for technical assistance, such as adding or removing establishments due to acquisitions and mergers.
Regardless of the reason, employers who were not able to meet the March 31 deadline have a short reprieve to submit their 2017 EEO-1 report data. The extension applies to 2018 only. Next year’s deadline will be March 31, 2019.
Originally Published By
ThinkHR.com
by admin | Apr 25, 2018 | Benefit Management, Benefit Plan Tips, Tricks and Traps
Curious about when you should notify a participant about a change to their health care plan?
The answer is that it depends!
Notification must happen within one of three time frames: 60 days prior to the change, no later than 60 days after the change, or within 210 days after the end of the plan year.
For modifications to the summary plan description (SPD) that constitute a material reduction in covered services or benefits, notice is required within 60 days prior to or after the adoption of the material reduction in group health plan services or benefits. (For example, a decrease in employer contribution is a material reduction in covered services or benefits. So is a material modification in any plan terms affecting the content of the most recent summary of benefits and coverage (SBC).) While the rule here is flexible, the definite best practice is to give advance notice. For collective practical purposes, employees should be told prior to the first increased withholding.
However, if the change is part of open enrollment, and communicated during open enrollment, this is considered acceptable notice regardless of whether the SBC, SPD, or both are changing. Essentially, open enrollment is a safe harbor for all 60-day prior/60-day post notice requirements.
Finally, changes that do not affect the SBC and are not a material reduction in benefits must be communicated and summarized within 210 days after the end of the plan year.
By Danielle Capilla
Originally Published By United Benefit Advisors
by admin | Apr 13, 2018 | ACA, Benefit Management, Group Benefit Plans
States that permit carriers to renew medical policies without adopting various Affordable Care Act (ACA) requirements may continue to do so through 2019, according to a bulletin released April 9, 2018, by the U.S. Department of Health and Human Services. The bulletin extends transitional relief for non-ACA-compliant policies for another year. The affected category of non-ACA-compliant policies, available in some individual and small group insurance markets, is commonly referred to as grandmothered.
By way of background, the ACA imposes numerous requirements on health plans. Whether a specific requirement applies, however, depends in part on the type of plan – and grandfathers and grandmothers are not the same.
Grandfathers
First, a grandfathered health plan is one that was established no later than March 23, 2010, when the ACA was enacted. The plan can maintain grandfathered status indefinitely, as long as it does not make certain changes to reduce its benefits or increase the employee’s out-of-pocket costs. Basic ACA rules, such as coverage for children up to age 26 and prohibiting annual and lifetime dollar limits on essential health benefits, apply to all plans. A plan that maintains grandfathered status, however, is exempt from many other ACA rules, such as coverage mandates for preventive care, and small group market rules for essential health benefits and adjusted community rating.
Grandmothers
A grandmothered policy does not have grandfathered plan status. It is an individual or small group policy originally issued before 2014 that has been allowed to renew year after year in accordance with the state’s insurance laws. Grandmothering does not apply to policies issued in the large group market. Most states that permit grandmothering also limit small group policies to groups with up to 50 employees.
Depending on the specific state’s rules, a grandmothered policy may be exempt from various ACA rules that otherwise would have taken effect in 2014, such as required coverage for all categories of essential health benefits and adjusted community rating. Currently about 30 states allow some type of grandmothering for individual policies or small group policies, or both, but the details vary from state to state.
States that allow grandmothering may continue to do so for renewals through October 1, 2019, provided the policy ends by December 31, 2019. Note, however, that even if the state’s insurance laws allow grandmothering, carriers are not required to continue renewing non-ACA policies.
What This Means
In summary, state insurance laws continue to control the options, provisions, and requirements that apply to group policies issued in their state. (Self-funded plans are not subject to state insurance laws.) For information about your state’s current insurance laws, refer to a carrier or broker that is licensed to sell products in your state.
Originally posted on ThinkHR.com
by admin | Apr 6, 2018 | Benefit Management, Employee Benefits, ERISA
The Department of Labor’s new claim rules for disability benefits took effect April 2, 2018. The changes were announced over a year ago, but the effective date was delayed to give insurers, employers, and plan administrators adequate time for implementation. Although we’ve reported on the key issues in this blog previously, now seems like a good time for a refresher on how the new rules affect employer plans.
Affected Plans
The new claim rules apply to disability benefits provided under plans covered by the Employee Retirement Income Security Act (ERISA); that is, plans sponsored by private-sector employers. Then the new rules apply if the ERISA plan must make a determination of disability in order for the claimant to obtain the benefit. Group short- and long-term disability plans are the most common examples, but pension, 401(k), and deferred compensation plans also may be affected.
Many plans do not make their own determination of disability, but instead condition the plan’s benefit on another party’s determination. For instance, employer plans that base the benefit on a disability determination made by the Social Security Administration (SSA) are not affected by the new rules.
New Rules
For ERISA plans affected by the new rules, the following additional requirements apply to disability claims filed on or after April 2, 2018:
- Disclosure Requirements: Benefit denial notices must explain why the plan denied a claim and the standards used in making the decision. For example, the notices must explain the basis for disagreeing with a disability determination made by the SSA if presented by the claimant in support of his or her claim.
- Claim Files and Internal Protocols: Benefit denial notices must include a statement that the claimant is entitled to request and receive the entire claim file and other relevant documents. (Previously this statement was required only in notices denying benefits on appeal, not on initial claim denials.) The notice also must include the internal rules, guidelines, protocols, standards or other similar criteria of the plan that were used in denying a claim or a statement that none were used. (Previously it was optional to include a statement that such rules and protocols were used in denying the claim and that the claimant could request a copy.)
- Right to Review and Respond to New Information Before Final Decision: Plans are prohibited from denying benefits on appeal based on new or additional evidence or rationales that were not included when the benefit was denied at the claims stage, unless the claimant is given notice and a fair opportunity to respond.
- Conflicts of Interest: Claims and appeals must be adjudicated in a manner designed to ensure the independence and impartiality of the persons involved in making the decision. For example, a claims adjudicator or medical or vocational expert could not be hired, promoted, terminated or compensated based on the likelihood of the person denying benefit claims.
- Deemed Exhaustion of Claims and Appeal Processes: If plans do not adhere to all claims processing rules, the claimant is deemed to have exhausted the administrative remedies available under the plan (unless exceptions for minor errors or other conditions apply). In that case, the claimant may immediately pursue his or her claim in court. Plans also must treat a claim as re-filed on appeal upon the plan’s receipt of a court’s decision rejecting the claimant’s request for review.
- Coverage Rescissions: Rescissions of coverage, including retroactive terminations due to alleged misrepresentations or errors in applying for coverage, must be treated as adverse benefit determinations that trigger the plan’s appeals procedures.
- Notices Written in a Culturally and Linguistically Appropriate Manner: Benefit denial notices must be provided in a culturally and linguistically appropriate manner in certain situations. Specifically, if the claimant’s address is in a county where 10 percent or more of the population is literate only in the same non-English language, the notices must include a prominent statement in the relevant non-English language about the availability of language services. The plan would also be required to provide a verbal customer assistance process in the non-English language and provide written notices in the non-English language upon request.
Action Steps for Employers
Employers are reminded to work with their carriers, third-party administrators, and advisors to make sure their plans comply with the new requirements. Consider these steps:
- Identify all plans that are subject to ERISA. (Plans sponsored by governmental employers, such as cities and public school districts, and certain church plans, are exempt from ERISA.)
- Does the ERISA plan provide any benefit based on disability? If so, is the benefit conditioned on a determination of disability made by the plan or by another party, such as Social Security?
- For insured plans, such as group STD and LTD insurance plans, the carrier generally is responsible for compliance with ERISA’s claim rules. The employer, however, does have a duty to make reasonable efforts to ensure the carrier is complying.
- For self-funded plans, the employer is responsible for compliance. Although the employer may engage the services of a third-party claims administrator, the employer remains responsible for the plan’s compliance with all rules.
Originally Published By ThinkHR.com
by admin | Mar 28, 2018 | Benefit Management, Benefit Plan Tips, Tricks and Traps, Human Resources
As the costs of health care soar, many consumers are looking for ways to control their medical spending. Also, with the rise of enrollment in high deductible health plans, consumers are paying for more health care out-of-pocket. From medical savings accounts to discount plans for prescriptions, patients are growing increasingly conscious of prices for their healthcare needs. Price shopping procedures and providers allows you to compare prices so that you are getting the best value for your care.
Why do you need to look beyond your nearby and familiar providers and locations for healthcare? Here’s a hypothetical example: Chris is a 45-year old male in good physical health. During his last check-up he mentions to his doctor that he’s had some recent shortness of breath and has been more tired as of late. His doctor orders an EKG to rule out any problems. If Chris went to his local hospital for this procedure, it would cost $1150. He instead looks online and shops around to find other providers in his area and finds he can get the same procedure for $450 at a nearby imaging center. His potential savings is $700 simply by researching locations.
So where do you start when shopping around for your health care? A good place to begin is by researching your health plan online. Insurance companies will post cost estimates based on facility, physician, and type of procedure. Keep in mind that these are just estimates and may vary based on what coverage you are enrolled in. Another way to shop is by checking out websites that have compiled thousands of claims information for various procedures and locations to give an estimate of costs. However, deciphering whether a site is reporting estimates based on the “medical sticker price” of charges or rates for private insurance plans or Medicare is difficult. There are huge differences in prices at different providers for the exact same procedure. This is because contracts between insurance agencies and providers vary based on negotiated amounts. This makes it hard to get consistent pricing information.
Check out these sites that do a great job comparing apples to apples for providers:
- Healthcare Blue Book
- What Kelly Blue Book is to cars, Healthcare Blue Book is to medical pricing
- New Choice Health
- Reports on pricing of medical procedures, providers, quality of facilities, and customer feedback for healthcare in all 50 states
- The Leapfrog Group
- Publishes data on hospitals so patients can compare facilities and costs for treatments and procedures
After compiling all the information on prices and procedures, you can still call and negotiate costs with the location of your care. Fair Health Consumer has tips on how to negotiate with providers and plan for your healthcare needs.
Knowledge is POWER and when you spend time researching and comparing healthcare costs, you are empowering yourself! Exercising due diligence to plan for you and your family’s medical needs will save you money and give you confidence in your decisions for care.
