by admin | Nov 30, 2017 | ACA, Employee Benefits, IRS
On December 13, 2016, President Obama signed the 21st Century Cures Act (Cures Act) into law. The Cures Act provides a method for certain small employers to reimburse individual health coverage premiums up to a dollar limit through HRAs called “Qualified Small Employer Health Reimbursement Arrangements” (QSE HRAs). The provision went into effect on January 1, 2017. On October 31, 2017, the IRS released Notice 2017-67, providing guidance on the implementation and administration of QSE HRAs.
Unless an employer meets all the requirements for offering a QSE HRA, previous IRS guidance prohibiting the reimbursement of individual premiums directly or indirectly, after- or pre-tax, through an HRA, a Section 125 plan, a Section 105 plan, or any other mechanism, remains in full effect. Reimbursing individual premiums in a non-compliant manner will subject an employer to a Patient Protection and Affordable Care Act (ACA) penalty of $100 a day per individual it reimburses, with the potential for other penalties based on the mechanism of the non-compliant reimbursement.
If an employer fails to meet the requirements of providing a QSE HRA, it will be subject to a penalty of $100 per day per affected person for being a non-compliant group health plan. An arrangement will be a group health plan that is not a QSE HRA if it:
- Is not provided by an eligible employer (such as an employer that offers another group health plan to its employees).
- Is not provided on the same terms to all eligible employees.
- Reimburses medical expenses without first requiring proof of minimum essential coverage (MEC).
- Provides a permitted benefit in excess of the statutory dollar limits.
An arrangement’s failure to be a QSE HRA will not cause any reimbursement of a properly substantiated medical expense that is otherwise excludable from income to be included in the employee’s income or wages. Furthermore, an arrangement designed to reimburse expenses other than medical expenses (whether or not also reimbursing medical expenses) is neither a QSE HRA nor a group health plan. Accordingly, all payments under such an arrangement are includible in the employee’s gross income and wages. An employer’s failure to timely provide a compliant written notice does not cause an arrangement to fail to be a QSE HRA, but instead results in the penalty of $50 per employee, not to exceed $2,500.
Answers to Top Three FAQs about QSE HRAs
1, Which employers may offer a QSE HRA?
Employers with fewer than 50 full-time and full-time equivalent employees (under ACA counting rules) that do not offer a group health plan. Employers that do not offer a group health plan, but offer a retiree-only plan to former employees may offer a QSE HRA.
2. Which employers may not offer a QSE HRA?
- Employers with 50 or more full-time and full-time equivalent employees (under ACA counting rules).
- Employers of any size that offer a group health plan, including plans that only provide excepted benefits, such as vision or dental benefits.
- Employers that provide current employees with access to money from health reimbursement arrangements (HRAs) offered in prior years (through a carry-over).
- Employers that offer employees access to carryover amounts in a flexible spending account (FSA).
3. What are the rules for employers in a controlled group?
- Employers with less than 50 full-time and full-time equivalent employees (under ACA counting rules) may offer QSE HRAs, with the headcount including all employees across an entire controlled group.
- If one employer within a controlled group offers a QSE HRA, it must be offered to all employees within the entire controlled group (or each employer must offer an identical QSE HRA).
BY Danielle Capilla
Originally Published By United Benefit Advisors
by admin | Sep 27, 2017 | Benefit Plan Tips, Tricks and Traps, Employee Benefits, Human Resources
We’ve all been there – once or twice (or more)—when a child, spouse or family member has had to gain access to healthcare quickly. Whether a fall that requires stitches; a sprained or broken bone; or something more serious, it can be difficult to identify which avenue to take when it comes to walk-in care. With the recent boom in stand-alone ERs (Emergency Care Clinics or ECCs), as well as, Urgent Care Clinics (UCCs) it’s easy to see why almost 50% of diagnoses could have been treated for less money and time with the latter.
It’s key to educate yourself and your employees on the difference between the two so as not to get pummeled by high medical costs.
- Most Emergency Care facilities are open 24 hours a day; whereas Urgent Care may be open a maximum of 12 hours, extending into late evening. Both are staffed with a physician, nurse practitioners, and physician assistants, however, stand alone ECCs specialize in life-threatening conditions and injuries that require more advanced technology and highly trained medical personnel to diagnose and treat than a traditional Urgent Care clinic.
- Most individual ERs charge a higher price for the visit – generally 3-5 times higher than a normal Urgent Care visit would cost. The American Board of Emergency Medicine (ABEM) physicians’ bill at a higher rate than typical Family-Medicine trained Urgent Care physicians do (American Board of Family Medicine (ABFM). These bill rates are based on insurance CPT codes. For example, a trip to the neighborhood ER for strep throat may cost you more than a visit to a UC facility. Your co-insurance fee for a sprain or strain at the same location may cost you $150 in lieu of $40 at a traditional Urgent Care facility.
- Stand alone ER facilities may often be covered under your plan, but some of the “ancillary” services (just like visit rates) may be billed higher than Urgent Care facilities. At times, this has caused many “financial sticker shock” when they first see those medical bills. The New England Journal of Medicine indicates 1 of every 5 patients experience this sticker shock. In fact, 22% of the patients who went to an ECC covered by their insurance plan later found certain ancillary services were not covered, or covered for less. These services were out-of-network, therefore charged a higher fee for the same services offered in both facilities.
So, what can you and your employees do to make sure you don’t get duped into additional costs?
- Identify the difference between when you need urgent or emergency care.
- Know your insurance policy. Review the definition of terms and what portion your policy covers with regard to deductibles and co-pays for each of these facilities.
- Pay attention to detail. Understand key terms that define the difference between these two walk-in clinics. Most Emergency Care facilities operate as stand-alone ERs, which can further confuse patients when they need immediate care. If these centers, or their paperwork, has the word “emergency”, “emergency” or anything related to it, they’ll operate and bill like an ER with their services. Watch for clinics that offer both services in one place. Often, it’s very easy to disguise their practices as an Urgent Care facility, but again due to CPT codes and the medical boards they have the right to charge more. Read the fine print.
It’s beneficial as an employer to educate your employees on this difference, as the more they know – the lower the cost will be for the employer and employee come renewal time.
by admin | Sep 22, 2017 | Employee Benefits, Health & Wellness
On August 22, 2017, the United States District Court for the District of Columbia held that the U.S. Equal Employment Opportunity Commission (EEOC) failed to provide a reasoned explanation for its decision to adopt 30 percent incentive levels for employer-sponsored wellness programs under both the Americans with Disabilities Act (ADA) rules and Genetic Information Nondiscrimination Act (GINA) rules.
The court declined to vacate the EEOC’s rules because of the significant disruptive effect it would have. However, the court remanded the rules to the EEOC for reconsideration.
Based on the recent court decision to require the EEOC to reconsider its wellness program rules, does this mean that the EEOC rules no longer apply to employer wellness programs? No. For now, the current EEOC rules apply to employer wellness programs. However, employers should stay informed on the status of the EEOC’s reconsideration of the wellness program rules so that employers can change their wellness programs’ design, if necessary, to comply with new EEOC rules.
According to UBA’s free special report, “How Employers Use Wellness Programs,” 67.7 percent of employers who offer wellness programs have incentives built into the program, an increase of 8.5 percent from four years ago. Incentives are the most prevalent in the Central U.S. (76.1 percent), among employers with 500 to 999 employees (83.2 percent), and in the finance, insurance, and real estate industries (74.7 percent). The West offers the fewest incentives, with only 48.3 percent of their plans having rewards.
Across all employers, slightly more (45.4 percent) prefer wellness incentives in the form of cash toward premiums, 401(k)s, flexible spending accounts (FSAs), etc., versus health club dues and gift cards (40 percent). But among larger employers (500 to 1,000+ employees) cash incentives are more heavily preferred (63.2 percent) over gift certificates and health club dues (33.7 percent). Conversely, smaller employers (1 to 99 employees) prefer health club-related incentives (nearly 40 percent) versus cash (25 percent).
Download our free (no form!) special report, “How Employers Use Wellness Programs,” for more information on regional, industry and group size based trends surrounding prevalence of wellness programs, carrier vs. independent providers, and wellness program components.
For comprehensive information on designing wellness programs that create lasting change, download UBA’s whitepaper: “Wellness Programs — Good for You & Good for Your Organization”.
To understand legal requirements for wellness programs, request UBA’s ACA Advisor, “Understanding Wellness Programs and Their Legal Requirements,” which reviews the five most critical questions that wellness program sponsors should ask and work through to determine the obligations of their wellness program under the ACA, HIPAA, ADA, GINA, and ERISA, as well as considerations for wellness programs that involve tobacco use in any way.
By Danielle Capilla
Originally Published By United Benefit Advisors
by admin | Aug 10, 2017 | Employee Benefits, Human Resources
Death and loss touch all of us, usually many times throughout our lives. Yet we may feel unprepared and uncomfortable when grief intrudes into our daily routines. As a manager, when grief impacts your employees it’s helpful to have a basic understanding of what they are going through as well as ways you can help.
Experiencing Grief
Although we all experience grief in our own way, there are behaviors, emotions and physical sensations that are a common part of the mourning process. J. William Worden’s “Four Tasks of Mourning” will be experienced in some form by anyone who is grieving. These tasks include accepting the reality of the loss, experiencing and accepting our emotions, adjusting to life without the loved one, and investing emotional energy into a new and different life.
Commonly experienced emotions are sadness, anger, frustration, guilt, shock and numbness. Physical sensations include fatigue or weakness, shortness of breath, tightness in the chest and dry mouth.
Manager’s Role
When employees are mourning, it’s important to create a caring, supportive and professional work environment. In most cases, employees will benefit from returning to work. It allows them to resume a regular routine, focus on something besides their loss and boost their confidence by completing work tasks.
At the same time, bereaved employees may experience many challenges when returning to work. They may have poor concentration, be extremely tired, feel depressed or have a short temper and uncontrollable emotions.
As a manager, the best thing you can do is acknowledge the loss and maintain strong lines of communication. Even if you believe someone else is checking in with them, make sure you stay in touch and see if there is anything you can do.
Developing a Return to Work Plan
In order to help your employees have a smooth transition back to work you must listen and understand their needs. Some additional questions you’ll want to answer are:
- What are your company’s policies and procedures for medical and bereavement leave?
- What information do your employees want their co-workers to have and would they rather share this information themselves?
- Do they want to talk about their experience or would they rather focus on work?
- Do they need private time while at work?
- Does their workload and schedule need to be adjusted?
- Do they need help at home – child care, meals, house work, etc.?
- Are there others at work that may be experiencing grief of their own?
Helpful Responses for Managers
- Offer specific help – make meals, wash their car, walk their pet, or anything else that will make their life easier.
- Say something – it can be as simple as, “I’m so sorry for your loss.”
- Listen – be kind but honest.
- Respect privacy – honor closed doors and private moments.
- Expect tears – emotions can hit unexpectedly.
- Thank your staff – for everything they are doing to help.
Grieving is a necessity, not a weakness. It is how we heal and move forward. As a manager, being there for your employees during this time is important in helping them through the grieving process.
An Employee Assistance Program is a great resource for both you and your employees when grief comes to work.
By Kathyrn Schneider
Originally Posted By www.ubabenefits.com
by admin | Aug 7, 2017 | ACA, Employee Benefits, Health & Wellness
Preexisting conditions. While it’s no doubt this term has been a hot topic in recent months—and notably misconstrued—one thing has not changed; insurers cannot deny coverage to anyone with a preexisting condition. Now that House Resolution 1628 has moved to the Senate floor, what can employers and individuals alike expect? If passed by the Senate as is and signed into law; some provisions will take place as early as 2019—possibly 2018 for special enrollment cases. It’s instrumental for companies to gear up now with a plan on how to tackle open enrollment; regardless of whether your company offers medical coverage or not.
Under the current proposed American Health Care Act (AHCA) insurance companies can:
- Price premiums based on health care status/age. The AHCA will provide “continuous coverage” protections to guarantee those insured are not charged more than the standard rate as long as they do not have a break in coverage. However, insurers will be allowed to underwrite certain policies for those that do lapse—hence charging up to 30% more for a preexisting condition if coverage lapses for more than 63 days. This is more common than not, especially for those who are on a leave of absence for illness or need extensive treatment. In addition, under current law, insurers are only allowed to charge individuals 50 and older 3 times as much than those under this age threshold. This ratio will increase 5:1 under AHCA.
- Under the ACA’s current law employers must provide coverage for 10 essential health care benefits. Under AHCA, beginning as early as 2020, insurers will allow states to mandate what they consider essential benefit requirements. This could limit coverage offered to individuals and within group plans by eliminating high cost care like mental health and substance abuse. Not that it’s likely, but large employers could eventually opt out whether they want to provide insurance and/or choose the types of coverage they will provide to their employees.
It’s important to note that states must apply for waivers to increase the ratio on insurance premiums due to age, and determine what they will cover for essential health benefits. In order to have these waivers granted, they would need to provide extensive details on how doing so will help their state and the marketplace.
So what can employers do moving forward? It’s not too soon to think about changing up your benefits package as open enrollment approaches, and educating yourself and your staff on AHCA and what resources are out there if you don’t offer health coverage.
- Make a variety of supplemental tools available to your employees. Anticipate the coming changes by offering or adding more supplemental insurance and tools to your benefits package come open enrollment. Voluntary worksite benefits, such as Cancer, Critical Illness, and Accident Insurance handle a variety of services at no out-of-pocket cost to the employer. HSA’s FSA’s and HRA’s are also valuable supplemental tools to provide your employees if you’re able to do so. Along with the changes listed above, the AHCA has proposed to also increase the contribution amounts in these plans and will allow these plans to cover Over-the-Counter (OTC) medications.
- Continue to customize wellness programs. Most companies offer wellness programs for their employees. Employers that provide this option should continue advancing in this area. Addressing the specific needs of your employees and providing wellness through various platforms will result in the greatest return on investment; and healthier employees to boot. Couple this with frequent evaluations from your staff on your current program to determine effectiveness and keep your wellness programs on point.
- Educate, educate, educate—through technology. Regardless if you employ 10 or 10,000, understanding benefit options is vital for your employees; what you have to offer them and what they may need to know on their own. Digital platforms allow individuals to manage their healthcare benefits and stay in the know with valuable resources at their fingertips. There’s no limit on the mediums available to educate your employees on upcoming changes. Partnering with a strong benefit agency to maximize these resources and keep your employees “in the know” during a constantly changing insurance market is a great way to start.
by admin | Jul 28, 2017 | Employee Benefits, Financial Planning, Retirement
Over the past few years, we’ve seen tremendous growth in Financial Wellness Programs. Actually, as indicated in a recent report by Aon Hewitt, 77% of mid- to large-size companies will provide at least one financial wellness service in 2017; with 52% of employers providing services in more than 3 financial categories. So what are the advantages of these programs and how can the current workforce make the most out of them?
Program Advantages
- They educate employees on financial management. It’s no doubt, poor income management and cash-flow decisions increase financial stress. This stress has a direct impact on an employee’s physical, mental and emotional state—all which can lead to productivity issues, increased absenteeism, and rising healthcare costs. Financial wellness tools in the workplace can not only support employees in various areas of their finances by expanding income capacity, but can create long-lasting changes in their financial habits as well.
- They give a foothold to the employer. As more employers are recognizing the effect financial stress has on their employees in the workplace, they’re jumping on board with these programs. As people are extending the length of their careers, benefits like these are an attractive feature to the workforce and new job seekers alike. In fact, according to a recent survey by TIAA, respondents were more likely to consider employment with companies who provide free financial advice as part of their benefit package.
Program Credentials
While financial wellness benefits may differ among companies, one thing is certain—there are key factors employers should consider when establishing a successful program. They should:
- Give sound, unbiased advice. Financial wellness benefits should be free to the employee—no strings attached. Employees should not be solicited by financial institutions or financial companies that only want to seek a profit for services. Employers should research companies when shopping these programs to determine the right fit for their culture.
- Encompass all facets. A successful program should cover all aspects of financial planning, and target all demographics. These programs should run the gamut, providing resources for those with serious debt issues to those who seek advanced estate planning and asset protection. Services should include both short-term to long-term options that fit with the company’s size and culture. Popular programs implement a variety of tools. Employers should integrate these tools with other benefits to make it as seamless as possible for their employees to use.
- Detail financial wellness as a process, not an event. Strengthening financial prosperity is a process. When determining the right fit for your company, continued coaching and support is a must. This may require evaluating the program and services offered every year. Employees need to know that while they have the initial benefit of making a one-time change, additional tools are at their disposal to shift their financial mindset; strengthening their financial habits and behaviors down the road.
Employees must understand the value Financial Wellness Programs can provide to them as well. If your company offers these benefits, keep a few things in mind:
- Maximize the program’s services. Utilize your financial workplace benefits to tackle life’s financial challenges. Most programs offer financial mentoring through various mediums. Seek advice on your financial issues and allow a coach/mentor to provide you with practical strategies, alternatives and actionable steps to reduce your financial stress.
- Take advantage of other employee benefits. Incorporate other benefits into your financial wellness program. Use financial resources to help you run projections and monitor your 401k. Budget your healthcare costs with these tools. Research indicates those who tap into these financial wellness programs often are more likely to stay on track than those who don’t.
- Evaluate your progress. Strengthening your financial well-being is a process. If your employer’s financial wellness program provides various tools to monitor your finances, use them. Weigh your progress yearly and take advantage of any support groups, webinars, or individual one-on-one counseling sessions offered by these programs.
As the workforce continues to evolve, managing these programs and resources effectively is an important aspect for both parties. Providing and utilizing a strong, effective Financial Wellness Benefits Program will set the foundation for a lifetime of financial well-being.
