2014 Year-End Employee Benefit Plan Food for Thought

Fraser Trebilcock Employee Benefits Attorney Health Care Law HIPAAAs the year winds down, it’s important to take stock of plan amendment and notice deadlines, as well as planning for 2015. To guide you through the process, we’ve put together a list that includes all of our Employee Benefit Client Alerts from 2014 as well as other food for thought.

Consider Cafeteria Plan Amendments:

      1. Ensure that the $2,500 cap on salary reductions for Health Flexible Spending Accounts (FSAs) is documented in the FSA/cafeteria plan documents by December 31, 2014 (went into effect in 2013, required in plan documents by December 31, 2014). Continue reading 2014 Year-End Employee Benefit Plan Food for Thought

Deadline Approaching for Employer Compliance with Pay or Play: Cash Outs and Affordability (New Guidance)

Fraser Trebilcock Employee Benefits Attorney Health Care Law HIPAAUnless transition relief applies, applicable large employers must comply with the Employer Shared Responsibility Mandate (i.e., Pay or Play) effective January 1, 2015.  Under Pay or Play, applicable large employers are required, among other things, to offer affordable medical coverage which provides minimum value to their full-time employees.  Although numerous guidance exists regarding determining whether coverage offered is affordable, this Client Alert focuses on the impact of cashable credits offered under a section 125 cafeteria plan.

Continue reading Deadline Approaching for Employer Compliance with Pay or Play: Cash Outs and Affordability (New Guidance)

Client Alert: HIPAA HPID Deadline Delayed until Further Notice

Fraser Trebilcock Employee Benefits Attorney Health Care Law HIPAAOn the eve of the HPID November 5, 2014 deadline, CMS announced that enforcement of the HPID requirements is delayed, until further notice.

“Effective October 31, 2014, the Centers for Medicare & Medicaid Services (CMS) Office of e-Health Standards and Services (OESS), the division of the Department of Health & Human Services (HHS) that is responsible for enforcement of compliance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) standard transactions, code sets, unique identifiers and operating rules, announces a delay, until further notice, in enforcement of 45 CFR 162, Subpart E,

Continue reading Client Alert: HIPAA HPID Deadline Delayed until Further Notice

October 15: Medicare Part D Notice of Creditable (or Non-Creditable) Coverage

Fraser Trebilcock Employee Benefits Attorney Health Care Law HIPAAMedicare Part D notices (of either creditable or non-creditable coverage) are due for distribution prior to October 15th.

As you know, if you as an employer offer prescription coverage to any Medicare Part D eligible employees (whether or not retired), or Medicare Part D Medicare-eligible spouses or dependents, you must provide those individuals with a Notice of Creditable or Non-Creditable Coverage to advise them whether your drug plan’s total gross value is at least as valuable as the standard Part D coverage (i.e., creditable). Medicare Part D notices must be provided to Medicare-eligible individuals prior to October 15th of each year.

Continue reading October 15: Medicare Part D Notice of Creditable (or Non-Creditable) Coverage

Client Alert: IRS Releases Draft Instructions and Q&As re: Employer Information Reporting Requirements under the ACA

The IRS has recently released draft instructions to the employer reporting drafted forms released over a month ago.
Continue reading Client Alert: IRS Releases Draft Instructions and Q&As re: Employer Information Reporting Requirements under the ACA

Health Care Reform: Where Do We Go From Here?

Over the past year, health care reform has been the top of everyone’s “hot topic list.”  Now that the rollout and implementation are in process, where do we go from here?

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Health Care Reform: Where Do We Go from Here?

imgresOver the past year, health care reform has been the top of everyone’s “hot topic list.”  Now that the roll-out and implementation are in process, where do we go from here? On September 9th, Fraser Trebilcock attorney Michael James will give a presentation at the Lansing Regional Chamber to answer that and other questions.

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IRS Releases Draft Forms For Employer Information Reporting Requirements under the ACA

Fraser Trebilcock Employee Benefits Attorney Health Care Law HIPAAAs set forth in our Client Alert dated March 11, 2014, the IRS requires employers and health insurance issuers to report on the health coverage offered and/or provided to individuals beginning calendar year 2015.

Continue reading IRS Releases Draft Forms For Employer Information Reporting Requirements under the ACA

Conflicting Rulings on Obamacare Component

Fraser Trebilcock Health Care Attorney Jonathan RavenTwo U.S. appeals courts issued conflicting rulings today on a major component of the Affordable Care Act.

“At issue here,” said Fraser Trebilcock attorney Jonathan Raven, ” is whether or not individuals can receive subsidies for health insurance in states that use the federal exchange, or if those subsidies are available to taxpayers in states that started their own state exchanges, which eliminates millions of people in states using the federal exchange.  Essentially, we’re talking about the “affordable” portion of the affordable care act. And today, two appeals courts reached two opposite conclusions.” Continue reading Conflicting Rulings on Obamacare Component

PCORI Fees Due by July 31, 2014 for Plan Sponsors of Certain Applicable Self-Funded Health Plans

Please let this serve as a reminder that the PCORI fee is due by July 31st and must be reported on Form 720.  The fee will be used to partially fund the Patient-Centered Outcomes Research Institute which was implemented as part of the Patient Protection and Affordable Care Act.

Continue reading PCORI Fees Due by July 31, 2014 for Plan Sponsors of Certain Applicable Self-Funded Health Plans