IRS Announces HSA Limits for 2020

IRS Announces HSA Limits for 2020

On May 28, 2019, the Internal Revenue Service (IRS) released Revenue Procedure 2019-25 announcing the annual inflation-adjusted limits for health savings accounts (HSAs) for calendar year 2020. An HSA is a tax-exempt savings account that employees can use to pay for qualified health expenses.
To be eligible for 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.

The limits vary based on whether an individual has self-only or family coverage under an HDHP. The limits are as follows:

  • 2020 HSA contribution limit:
    • Single: $3,550 (an increase of $50 from 2019)
    • Family: $7,100 (an increase of $100 from 2019)
    • Catch-up contributions for those age 55 and older remains at $1,000
  • 2020 HDHP minimum deductible (not applicable to preventive services):
    • Single: $1,400 (an increase of $50 from 2019)
    • Family: $2,800 (an increase of $100 from 2019)
  • 2020 HDHP maximum out-of-pocket limit:
    • Single: $6,900 (an increase of $150 from 2019)
    • Family: $13,800* (an increase of $300 from 2019)

*If the HDHP is a nongrandfathered plan, a per-person limit of $8,150 also will apply due to the Affordable Care Act’s cost-sharing provision for essential health benefits.

Originally posted on ThinkHR.com

IRS Extends Deadline for Employers to Furnish Forms 1095-C and 1095-B

IRS Extends Deadline for Employers to Furnish Forms 1095-C and 1095-B

On November 29, 2018, the IRS released Notice 2018-94 to extend the due date for employers to furnish 2018 Form 1095-C or 1095-B under the Affordable Care Act’s employer reporting requirement. Employers will have an extra month to prepare and distribute the 2018 form to individuals. The due dates for filing forms with the IRS are not extended.

Background

Applicable large employers (ALEs), who generally are entities that employed 50 or more full-time and full-time-equivalent employees in 2017, are required to report information about the health coverage they offered or did not offer to certain employees in 2018. To meet this reporting requirement, the ALE will furnish Form 1095-C to the employee or former employee and file copies, along with transmittal Form 1094-C, with the IRS.
Employers, regardless of size, that sponsored a self-funded (self-funded) health plan providing minimum essential coverage in 2018 are required to report coverage information about enrollees. To meet this reporting requirement, the employer will furnish Form 1095-B to the primary enrollee and file copies, along with transmittal Form 1094-B, with the IRS. Self-funded employers who also are ALEs may use Forms 1095-C and 1094-C in lieu of Forms 1095-B and 1094-B.

Extended Due Dates

Specifically, Notice 2018-94 extends the following due dates:

  • The deadline for furnishing 2018 Form 1095-C, or Form 1095-B, if applicable, to employees and individuals is March 4, 2019 (extended from January 31, 2019).
  • The deadline for filing copies of the 2018 Forms 1095-C, along with transmittal Form 1094-C (or copies of Forms 1095-B with transmittal Form 1094-B), if applicable, remains unchanged:
    • If filing by paper, February 28, 2019.
    • If filing electronically, April 1, 2019.

The extended due date applies automatically so employers do not need to make individual requests for the extension.

More Information

Notice 2018-94 also extends transitional good-faith relief from certain penalties to the 2018 employer reporting requirements.
Lastly, the IRS encourages employers, insurers, and other reporting entities to furnish forms to individuals and file reports with the IRS as soon as they are ready.
by Kathleen Berger
Originally posted on ThinkHR.com

PCORI Fee Increase for Health Plans

PCORI Fee Increase for Health Plans

On November 5, 2018, the Internal Revenue Service (IRS) released Notice 2018-85 to announce that the health plan Patient-Centered Outcomes Research Institute (PCORI) fee for plan years ending between October 1, 2018 and September 30, 2019 will be $2.45 per plan participant. This is an increase from the prior year’s fee of $2.39 due to an inflation adjustment.

Background

The Affordable Care Act created the PCORI to study clinical effectiveness and health outcomes. To finance the nonprofit institute’s work, a small annual fee — commonly called the PCORI fee — is charged on group health plans.
The fee is an annual amount multiplied by the number of plan participants. The dollar amount of the fee is based on the ending date of the plan year. For instance:

  • For plan year ending between October 1, 2017 and September 30, 2018: $2.39.
  • For plan year ending between October 1, 2018 and September 30, 2019: $2.45.

Insurers are responsible for calculating and paying the fee for insured plans. For self-funded health plans, however, the employer sponsor is responsible for calculating and paying the fee. Payment is due by filing Form 720 by July 31 following the end of the calendar year in which the health plan year ends. For example, if the group health plan year ends December 31, 2018, Form 720 must be filed along with payment no later than July 31, 2019.
Certain types of health plans are exempt from the fee, such as:

  • Stand-alone dental and/or vision plans;
  • Employee assistance, disease management, and wellness programs that do not provide significant medical care benefits;
  • Stop-loss insurance policies; and
  • Health savings accounts (HSAs).

HRAs and QSEHRAs

A traditional health reimbursement arrangement (HRA) is exempt from the PCORI fee, provided that it is integrated with another self-funded health plan sponsored by the same employer. In that case, the employer pays the PCORI fee with respect to its self-funded plan, but does not pay again just for the HRA component. If, however, the HRA is integrated with a group insurance health plan, the insurer will pay the PCORI fee with respect to the insured coverage and the employer pays the fee for the HRA component.
A qualified small employer health reimbursement arrangement (QSEHRA) works a little differently. A QSEHRA is a special type of tax-preferred arrangement that can only be offered by small employers (generally those with fewer than 50 employees) that do not offer any other health plan to their workers. Since the QSEHRA is not integrated with another plan, the PCORI fee applies to the QSEHRA. Small employers that sponsor a QSEHRA are responsible for reporting and paying the PCORI fee.

PCORI Nears its End

The PCORI program will sunset in 2019. The last payment will apply to plan years that end by September 30, 2019 and that payment will be due in July 2020. There will not be any PCORI fee for plan years that end on October 1, 2019 or later.

Resources

The IRS provides the following guidance to help plan sponsors calculate, report, and pay the PCORI fee:

Originally posted on thinkhr.com

Using Your Health Savings Account

Using Your Health Savings Account

According to recent estimates by Fidelity Investments, a couple will incur an estimated $280,000 worth of medical expenses after turning 65 years of age. They estimate this cost every year and when they publish it, I can’t help but have an anxiety spike as I ponder the reality of that number. Even if they are off and have over-estimated by 50%, the remaining number is still very hard for me to swallow. And, as anxiety has habit of doing, it sends me into panic mode and I scramble to reevaluate my retirement planning in an attempt to ward off the eventual doom and gloom that has settled on the far horizon of my life.
After a few deep breaths, I settle down and remind myself that I have a health savings account (HSA) that I have faithfully been contributing to over the past several years and that I plan to continue contributing to as long as I am eligible to do so. HSAs are a great way to plan for medical expenses, either in the future when you retire, or now when you or a member of your family incurs qualified medical expenses. Here’s the run down on how they work.
HSAs are a savings account option that allows individuals that are covered by a high deductible health plan (and that are not covered by any type of insurance other than a high deductible health plan), to set aside a certain amount of their income on a pre-tax basis to pay for medical expenses that arise. Unlike health flexible spending accounts that are similar in that individuals can set aside pre-tax dollars to pay for qualified medical expenses, funds put into an HSA are not forfeited at the end of the year if you don’t spend them. Said differently, HSAs don’t have the “use it or lose it” component. If you don’t use it, you keep it, and if you do that year after year, the balance in your HSA can grow exponentially!
An HSA works essentially like this. Each year the government sets a maximum amount that qualified individuals are able to put into an HSA on a pre-tax basis. For 2018, this amount is set at $3,450 for individuals that have single coverage under a high deductible health plan (HDHP) or $6,900 for individuals with family coverage under an HDHP plan. Then, these funds can be used to pay for qualified medical expenses that are incurred. This would be for out-of-pocket expenses that aren’t covered by their health plan such as copays, deductibles or qualified expenses not covered by the plan.
The concept for HDHPs is that they are a type of consumer-driven health plan that results in individual consumers having more “skin in the game,” leading them to be more conscientious consumers of health care, thereby helping to control the rising costs of health care. To assist individuals to pay for the higher costs they are responsible for prior to meeting the higher deductible, the government was willing to also have more skin in the game by forfeiting tax dollars and allowing HSA contributions to be made on a pre-tax basis to pay for these costs. Employers who allow employees to contribute to HSAs on a pre-tax basis also benefit by reducing the amount of FICA taxes that they are required to pay.
The goal of the HSA was not only to help pay for these higher, pre-deductible expenses, but also to provide a mechanism for individuals to save for medical expenses once they reach retirement. After all, discussions and debates continue regarding whether or not Medicare will continue to exist in the years to come.
If you contribute to an HSA and then use those funds for qualified medical expenses, you pay no taxes on those funds. In essence, you are lowering your expense by the amount of taxes you save. If, however, you dip into your HSA to pay for non-qualified expenses, then you are subject to taxes on those funds plus a 10% tax penalty.
Some individuals balk at contributing to an HSA because they feel they will not incur qualified medical expenses in the coming year. Other individuals limit their HSA contributions to the amount of qualified medical expenses they expect to incur in the coming year. Still others try to contribute the maximum amount each year regardless of what they anticipate their costs being. Why?
In addition to contributing dollars on a pre-tax basis, many banks that offer HSAs also offer investment options for those accounts, so that you can increase your funds through investments on top of the on-going contributions that you deposit. And, this investment growth is also available to you on a tax-free basis as long as the funds are used for qualified medical expenses! I find this refreshingly reassuring as I peek into my account and see that it is growing, and it not just because I’m dumping money into it. So max-funding an HSA and investing those dollars allow you to earn even more dollars on top of the pre-tax dollars. I look at this as free money!
Because of this growth potential, leaving funds in the account even when you do have qualified medical expenses can be an advantageous investment maneuver. What? Not use the funds when you have a qualified expense? Yep. You are not required to take funds out of your HSA at the time that a qualified expense occurs. You can leave that money in your HSA and, as long as you keep your receipts showing that you paid for those qualified expenses, you can wait to reimburse yourself for that expense at any time in the future, even if you are no longer covered by an HDHP when you decide to reimburse yourself. You see, although you are only eligible to contribute to an HSA when you are covered by an HDHP, you can take the money out for qualified expenses at any time in the future. I love this option. I put as much money into my HSA as I can, and as long as I have the funds in my personal operating account, I pay for qualified medical expenses with that money. I save all of those receipts and if in the future I’m short on money in my operating account for whatever reason, I can then reimburse myself for prior qualified medical expenses from my HSA. If I never need to do this, good for me; I leave the funds in the HSA and I continue to reap investment growth. There’s that free money again!
But what if I reach retirement and I’m still healthy? What if I manage to accumulate $140,000 in my HSA and I end up NOT having $140,000 in medical expenses? Will I encounter a “use it or lose it” option at this point? Nope. If I’m fortunate enough to be healthy with minimal medical expenses after turning 65, the funds in my HSA can operate exactly like my 401(k). Meaning, if I withdraw the funds for non-medical expenses after turning 65, those funds are subject to taxes, but they are no longer subject to the 10% tax penalty that I would have incurred if I used the funds for non-medical expenses prior to turning 65. And, just like a 401(k), the anticipated tax rate after I turn 65 is expected to be lower so I won’t pay as much in tax as I would have if I had taken those funds in my paycheck back when I was younger. Although my goal is to contribute to both my 401(k) and my HSA, I try to max-fund my HSA first and then I fund my 401(k) with as much as I can after that. Why? Because, once I reach 65 my HSA performs just like my 401(k) if I choose to spend the dollars on non-medical expenses. However, if I do have medical expenses, the funds I take from my HSA to pay for those expenses are “tax-free.” If I had to use money from my 401(k) for medical expenses, that money would be taxed!
By Vicki Randall
Originally Published By United Benefit Advisors

6 Questions on Dependent Care Spending Accounts

6 Questions on Dependent Care Spending Accounts

School’s out! Summer is here, and it’s the time of year when working parents have questions about using their Dependent Care Spending Accounts (DCSAs). Are summer camp expenses eligible? What about day versus overnight camps? Employers and benefit advisors want to be ready with answers about this valuable benefit program.
The following are the top summertime questions about DCSAs and reimbursable expenses:

1. What are the basic rules for reimbursable expenses?

Dependent care expenses, such as babysitting and daycare center costs, must be work-related to qualify for reimbursement. Work-related means the expenses are for the care of the employee’s child under age 13 to allow the employee to work. If the employee is married and filing jointly, the employee’s spouse also must be gainfully employed or looking for work (unless disabled or a full-time student).
In some cases, expenses to care for a disabled dependent, regardless of age, may be reimbursable. This article focuses on expenses for children under 13 since those are by far the most common type of DCSA reimbursement.

2. One of our employees and his family are taking a two-week vacation this summer, but his children’s daycare center will charge its regular fee. Are the expenses reimbursable even if the employee and spouse are off work?

Yes. In most cases, expenses are not eligible unless the dependent care services are necessary for the parents to work, but some exceptions apply. The IRS rules for DCSAs provide that expenses during short, temporary absences are eligible if the employee has to pay the child’s care provider. Absences of up to two weeks are automatically considered short, temporary absences. Depending on the circumstances, longer absences also may qualify.

3. During the school year, our employee uses her DCSA for her 10-year old’s after-school daycare center expenses. This summer, the child’s daycare will be provided by her 20-year old sister. If the older daughter bills for her services, are the costs eligible for reimbursement?

The answer depends on whether the employee or spouse can claim the older daughter as a tax dependent. If the older daughter can be claimed as a dependent, whether or not the employee actually claims her, she is not a qualifying dependent care provider under the DCSA rules.
If the older daughter cannot be claimed as a tax dependent, her charges for providing care are eligible expenses. The specific rule is that a child of the employee, whom the employee cannot claim as a dependent, may be a qualifying provider if the child is age 19 or older by the end of the year.
Note that the employee’s spouse or the child’s parent is never a qualifying provider.

4. One of our employees has to pay an application fee and deposit before her child starts attending a daycare center this summer. Are those expenses eligible for reimbursement?

Prepaid expenses are eligible for DCSA reimbursement, provided the costs are required in order for the child to receive care. In this case, after the daycare center begins providing care, the employee can be reimbursed for the application fee and deposit she paid. On the other hand, if the employee cancels and her child does not attend, then the application fee and deposit are not eligible expenses.

5. An employee will pay day camp expenses for his 8-year-old son and overnight camp expenses for his 12-year-old daughter this summer. Are both types of expenses eligible for reimbursement?

The day camp expenses generally are reimbursable. Expenses for overnight camp, however, are not eligible since overnight care is not work-related.
Under the IRS rules for DCSAs, expenses for food, lodging, clothing, education, and entertainment are not reimbursable. If, however, such expenses are small, incidental expenses that cannot be separated from the cost of caring for the child, they may be included for reimbursement. For instance, the day camp may include lunch, snacks, and some sports activities in its basic fee, which would be eligible for reimbursement.

6. An employee’s children go to private year-round schools. He pays tuition for one child’s grade school and fees for the other child’s nursery school. Are both types of expenses eligible for reimbursement?

Educational expenses are not reimbursable, unless the educational services are merely incidental as part of a child care service. Expenses to attend kindergarten or a higher grade are educational, so the older child’s school fees are not eligible for DCSA reimbursement. (Expenses for before- or after-school care, however, may qualify as reimbursable expenses.)
On the other hand, expenses for a child in nursery school, preschool, or a similar program for children below the level of kindergarten are expenses for care. Such expenses are not considered educational even though the nursery school may include some educational activities.
For detailed information about expenses eligible for DCSA reimbursement, the IRS provides a helpful guide: Publication 503 “Child and Dependent Care Expenses”. Have a fun summer!
Originally Published By ThinkHR.com

IRS Issues Updated Employers Tax Guide to Fringe Benefits

IRS Issues Updated Employers Tax Guide to Fringe Benefits

Recently the Internal Revenue Service (IRS) issued its 2018 Publication 15-B, which informs
employers about employment tax treatment of fringe benefits.
Updates include:

  • the suspension of qualified bicycle commuting reimbursements from an employee’s income for any tax year after December 31, 2017 and before January 1, 2026;
  • the suspension of the exclusion for qualified moving expense reimbursements from an employee’s income for tax years after December 1, 2017 and before January 1, 2026 (with exceptions for active duty U.S. Armed Forces members who move because of a permanent change of station);
  • limits on employers’ deductions for certain fringe benefits including meals and transportation commuting; and
  • the definition of items that aren’t tangible personal property for purposes of employee achievement awards.

Originally Published By United Benefit Advisors