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Updates to Fines for ACA, HIPAA, and MSP Violations
December 20, 2023
Recent updates have been made to the civil penalties for HIPAA violations, ACA requirements, and Medicare Secondary Payer rules. Increases in these fines means it is more important than ever to review your documents and procedures to ensure compliance.
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IRS Releases 2024 Qualified Benefit Plan Limits
November 9, 2023
The IRS has announced 2024 contribution limits for Flexible Spending Accounts, Adoption Assistance Programs and Commuter Plans.
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Illinois Will Require Commuter Benefits in Chicago Area
September 12, 2023
The State of Illinois passed the Transportation Benefits Program Act (Public Act 103-0291), requiring employers in specified areas around Chicago to provide commuter benefits to specified employees as of January 1, 2024.
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Benefits-Related Washington News to Watch
August 31, 2020
While the two houses of Congress are in recess until September, they have been told to remain available for a vote on additional legislation related to COVID-19. Learn more about recently proposed legislation that could impact the health benefits industry.
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2020 Qualified Benefit Plan Limits Released
November 6, 2019
The Internal Revenue Service (IRS) has released additional qualified benefit plan contribution limits for 2020, including limits for flexible spending accounts (FSA) and Commuter Benefit accounts.
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IRS Notice with HSA Implications Expands “Preventive” Care to Include Certain Chronic Conditions
August 27, 2019
The IRS has issued Notice 2019-45, in which it identifies certain chronic health conditions whose treatments will now be considered “preventive.” As a result, such treatments can be covered by a health insurance plan without first meeting the minimum deductibles generally required of high deductible health plans (HDHPs) for health savings account (HSA) contribution eligibility purposes.
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President Trump Issues Executive Order Addressing Medical Price Transparency & HSA/FSA/HRA Issues
On June 24, 2019, President Trump signed an Executive Order designed to “enhance the ability of patients to choose the healthcare that is best for them.” The order directs various departments of the government to develop regulations and materials aimed at improving transparency in healthcare pricing and quality. This includes developing rules to expand the use of health savings accounts (HSAs), health flexible spending arrangements (FSAs) and health reimbursement arrangements (HRAs).
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IRS Releases 2020 HSA Contribution & Coverage Limits
May 30, 2019
The IRS recently announced new Health Savings Account (HSA) contribution limits for 2020, asd well as High Deductible Health Plan (HDHP) deductible amounts and expense limits.
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What You Should Know About Employee Wellness Program Compliance
February 28, 2019
Corporate wellness programs are more popular than ever, gaining momentum in part due to the soaring cost of healthcare. However, deciphering a given wellness program’s compliance under the law is no simple task.
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Qualified Benefit Plan Limits
November 18, 2018
The IRS recently announced the following new limits for 2019:
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Important Plan Limits for 2024
December 20, 2023
On November 9,2023, the IRS issued IRS Revenue Procedure 2023-34, which address annual inflation adjustments for more than 60 tax provisions. Included are new limits for Flexible Spending Accounts, Commuter Benefits and various other code provisions.
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PCORI Fee Update for Plan Years Ending October 1, 2023, - September 30, 2024
December 20, 2023
On October 18, 2023, the IRS issued Notice 2023-70, announcing the adjusted applicable dollar amount for determining the Patient-Centered Outcomes Research Trust Fund (PCORTF) fee for policy years and plan years ending on or after October 1, 2023, and before October 1, 2024.
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Avoid Compliance Mistakes During Open Enrollment
December 20, 2023
Open enrollment is one of the busiest times of year for employee benefits professionals. It’s a stressful season that typically results in questions and complaints and comes with a high potential for both employer and employee mistakes.
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A Closer Look at ERISA Requirements – A Review of the Summary of Benefits and Coverage
December 20, 2023
The Summary of Benefits and Coverage (SBC) is a document that health insurance companies are required to provide to plan participants and beneficiaries under the Affordable Care Act (ACA). It's designed to help individuals better understand their health insurance coverage by providing a summary of key information in a standardized format.
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Tax Implications of Lifestyle Spending Accounts
December 20, 2023
Lifestyle Spending Accounts (LSAs) are a relatively new type of benefit that allows employers a great deal of flexibility, allowing employers to give their employees money to spend on products and services that will enhance their lives, but LSAs should not include expenses covered under any other insurance programs or pre-tax benefits.
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Medicare Secondary Payer Finalized Rules and FAQs
December 20, 2023
Though implementation dates for group health plans (GHP) arrangement information have been in place for several years, on October 11, 2023, the Centers of Medicare Medicaid Services (CMS) finalized regulations specifying when and how it will calculate and impose civil money penalties for violation of the Medicare Secondary Payer (MSP) reporting requirements for GHP and certain non-group health plan arrangements.
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A Closer Look at ERISA Requirements – A Review of the Summary Annual Report
August 24, 2023
The Summary Annual Report (SAR) is a summary of the information that has previously been reported by the plan on the most recent Form 5500 to the Department of Labor (DOL). Doing so ensures transparency as it requires the plan to regularly communicate funding and financial information to those who are relying on its benefits.
SARs are required each year for pension plans, including 401(k) plans, and for welfare plans unless an exemption applies. The exemption applies to those welfare benefit plans that have less than 100 participants or are completely unfunded (meaning all claims are paid through the employer’s general assets). -
COBRA Compliance - Required COBRA Notices and Deadlines
August 24, 2023
The Consolidated Omnibus Budget Reconciliation Act 1985 (COBRA) requires plan administrators to provide certain disclosures to plan participants, other covered dependents, and those who lose their health plan coverage and attain the status of qualified beneficiaries. Failing to meet COBRA requirements can result in significant consequences for the employer who is the Plan Sponsor, including penalties as well as potential liability to pay extensive medical bills if COBRA enrollment opportunities are missed.
One of the best ways an employer can ensure they are managing group health plan requirements appropriately and mitigating unnecessary risk and expenses is to know their notice responsibilities and to make sure they are met. -
Getting Back to Business After the End of the National Emergency
August 24, 2023
It has now been over three years since the National Emergency was announced in March 2020. As a result, there was a flood of relief directed at employee benefit plans. This included guidance issued by the Department of Labor (DOL) and Internal Revenue Service (IRS) to extend certain plan deadlines. The National Emergency continued for such a significant length of time, that returning to the normal administration of benefits, now that it has ended, may be difficult for those who have grown accustomed to extended deadline dates.
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IRS Provides Post-Pandemic Guidance on Preventive Care Expenses
August 24, 2023
The IRS has issued Notice 2023-37, providing information on expenses related to preventative care for the purposes of high deductible health plans (HDHPs) and eligibility for HSAs. This guidance modifies the position the IRS has previously taken.
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What Employers Need To Consider When Offering an HSA
August 24, 2023
More employers than ever are offering their employees a high deductible health plan (HDHP) with an HSA option to help keep costs down. Here are a few things to think about when first getting started.
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Meeting the “But For” Requirement of Dual-Purpose Expenses
August 24, 2023
Flexible Spending Accounts (FSAs) and Health Reimbursement Arrangements (HRAs) are designed to reimburse medical care expenses. IRS Code says that expenses must be for the “diagnosis, cure, mitigation, treatment or prevention of disease, or for the purpose of affecting any structure of function of the body”, but what if something can be used to cure a disease and for general health? In these cases you must use the "but for" test.
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How to Use Health FSA Forfeitures
May 25, 3023
Offering a Flexible Spending Account (FSA) is a great way for employers to retain and attract new talent and promote financial wellness. Recent studies reveal that participants are regularly forfeiting substantial FSA sums. What should an employer do with these forfeitures?
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HDHPs and Wellness Plans
May 25, 2023
High deductible health plans (HDHPs) can be great for employees. The premium savings mean more money in their paychecks. Pairing an HDHP with a Health Savings Account (HSA), can offer another tax-advantaged means of saving. Offering a wellness program is another way employers can help employees enrolled in an HDHP to manage their healthcare costs. Wellness programs can help employers reduce their benefit costs too. These programs can take many forms, so thoughtful analysis is needed to determine what features will best help both employers and their employees lower overall healthcare spending.
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Health FSAs — Why are Some Expenses Not Reimbursable?
May 25, 2023
When it comes to offering a Flexible Spending Account (FSA), employers do not usually have the capabilities or the time to manage all aspects of the plan, so it makes sense to contract with a third-party administrator (TPA) to carry out administrative functions, particularly the time-consuming task of claims processing.
So, what explanation can an employer provide when an employee complains that the TPA has denied their FSA claim?
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ERISA Requirements – A Closer Look at Participant Disclosures
May 25, 2023
ERISA imposes certain requirements on employers that offer health and benefit plans to employees. There are several distinct areas of ERISA compliance, which include maintaining compliant plan documents and corresponding operations, adhering to fiduciary obligations, meeting fidelity bonding requirements, submitting annual Department of Labor (DOL) reporting and providing participant disclosures.
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Compliance Alert: IRS Releases HSA Limits for 2024
May 17, 2023
The IRS has issued Revenue Procedure 2023-23, providing inflation-adjusted Health Savings Account (HSA) contribution amounts for calendar year 2024.
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COVID-19 Extended Deadlines Ending Soon
May 4, 2023
Informal guidance provided by the Department of Labor, Treasury Department, and Department of Health and Human Services has indicated that the COVID-19 Outbreak Period will end on July 10, 2023.
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ACA Employer Shared Responsibility Payments Increasing for 2024
March 23, 2003
The IRS has issued Revenue Procedure 2023-17 announcing the 2024 indexed adjustments to the amounts used to calculate employer shared responsibility payments under Internal Revenue Code Sections 4980H(a) and 4980H(b)(1).
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Nondiscrimination Testing - The Basics
March 9, 2023
Individuals enjoy a favorable tax advantage when their benefits are part of a cafeteria plan. Nondiscrimination testing shows whether tax-advantaged plans are discriminating in favor of highly compensated employees or key employees. All employers that provide a cafeteria plan must complete this testing by the last day of the plan year.
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Which Employee Benefit Plans Require Form 5500 Reporting?
March 9, 2023
You may know that Form 5500 filing is required for your 401(k) plan or your medical insurance, but were you aware that it must be done for other employee benefit plans as well? If you are unsure whether a plan requires a Form 5500 filing, read on.
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Understanding COBRA Qualifying Events and Employer Responsibilities
March 9, 2023
COBRA allows employees to continue coverage under their employer-sponsored health plan if they lose coverage due to a “qualifying event.” It also allows dependents of employees who were enrolled in the plan to continue their coverage. It is important for employers to recognize when a “qualifying event” occurs, as they are required to send impacted individuals an election notice explaining their COBRA rights and enrollment opportunities.
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Which Dependents are Covered by a Flexible Spending Account (FSA)?
March 9, 2023
In general, dependent care FSA funds can be used to cover children through age 13 and family members who cannot care for themselves; and health FSA and limited-purpose FSA funds can be used to pay for expenses of spouses and children through age 27, but there are some nuances to be aware of.
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Reducing 2022 Income Tax Liability is Still Possible with an HSA
March 9, 2023
Every January, employees collect W-2 forms and other information to file their income taxes. After crunching numbers, the amount of tax they owe the IRS may come as an unpleasant surprise. Once a tax year is closed there aren't many ways to reduce a tax bill, but a prior-year HSA contribution can help.
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COVID-19 National Emergency Expected to End May 11, 2023
February 2, 2023
President Biden has announced his intent to extend the national emergency concerning the COVID-19 pandemic through May 11, 2023. Associated deadline extensions for health and welfare plans would end July 10, 2023.
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Two-Year Extension on Telehealth Services Granted
January 5, 2023
The recently enacted Consolidated Appropriations Act of 2023 (CAA 2023) granted a two-year extension allowing high deductible health plans (HDHPs) to waive the deductible for telehealth and other remote care services without causing plan participants to lose the ability to contribute to an HSA.
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IRS Grants Permanent Extension to ACA Reporting Deadline
December 20, 2022
The IRS has issued final regulations granting a permanent, automatic extension of time to comply with the Affordable Care Act (ACA) reporting requirements.
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Temporary Relief Due to COVID Outbreak Period May Come to an End
December 15, 2022
When the COVID-related National Emergency will come to an end is on the minds of many health plan Sponsors and Administrators. The Public Health Emergency (PHE) is extended through January 11, 2023, and the National Health Emergency (NE) is set to expire March 1, 2023.
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Washington DC’s New Parking “Cash Out” Law Impacts Commuter Benefits
December 15, 2022
The Council of the District of Columbia has approved a new transportation benefit law that requires employers who provide parking benefits to also offer ‘clean-air’ transportation benefits. The law also requires employers to submit reporting and plans to the city. The new law applies to every employer with at least 20 persons located in Washington D.C. and offers its employees free or discounted parking.
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Does Your Health Plan Need a Dependent Eligibility Audit?
December 15, 2022
If you are not currently conducting ongoing verification audits or requiring employees to provide documentation when they enroll in benefits, then you should audit your plan. An eligibility audit is a type of compliance review that is used to ensure that dependents covered by the plan are eligible to enroll based on the plan’s eligibility rules, as well as state and federal regulations.
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Important 2023 Plan Limits
December 15, 2022
The IRS has released Revenue Procedures 2022-38 and 2022-24 including 2023 plan limits for Flexible Spending Accounts (FSA) and Commuter Benefits, limits related to Health Savings Accounts (HSA), high deductible health plans (HDHP) and various other code provisions.
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2023 PCORI Fee Update
December 15, 2022
On November 14, 2022, the IRS released Notice 2022-59, announcing the adjusted applicable dollar amount for determining the Patient-Centered Outcomes Research Trust Fund (PCORTF) fee for policy years and plan years ending on or after October 1, 2022, and before October 1, 2023.
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What to Consider When Transferring IRA Funds to an HSA
December 15, 2022
The Health Opportunity Patient Empowerment Act includes a provision which allows the owner of an Individual Retirement Account (IRA) to make a one-time, tax-free transfer into a Health Savings Account (HSA). This distribution gives HSA owners an additional way to fund their accounts and save on taxes while planning to cover future qualified medical expenses.
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Dependent Care: What It Means
December 15, 2022
In recent years, the Federal Government has passed several pieces of legislation to offer relief and much-needed flexibility to employers that offer dependent care assistance programs (DCAPs). But many employers are struggling to make these benefits attractive to all levels of their workforce who may not see the value in putting away pre-tax dollars for care of children.
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New Cafeteria Plan Changes Fix “Family Glitch” in ACA Subsidies
October 18, 2022
Last week, the Department of the Treasury and the Internal Revenue Service released regulations designed to close a loophole known as the “family glitch.”
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IRS Releases 2023 Qualified Benefit Plan Limits
October 18, 2022
The IRS has announced new Flexible Spending Account and Commuter contribution limits for 2023.
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Cyber Attacks: Why Russia and Korea are Targeting Health Plans
September 22, 2022
In March President Biden gave an official statement regarding Russian cyberattacks against the U.S. and in July the FBI warned of attacks on health plans by North Korea. All covered entities should be alert and enforce best practices.
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Is Your Flexible Spending Account Configured to Meet Your Company’s Needs?
September 22, 2022
FSA plans must be designed to meet the requirements defined in federal tax code, but employers have several opportunities to choose features that best fit the needs of their organization.
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Philadelphia Adds Commuter Benefit Requirement
September 22, 2022
On June 22, 2022, Philadelphia Mayor Jim Kenney, signed the Employee Commuter Transit Benefit ordinance. The ordinance takes effect on December 31, 2022, and requires employers with 50 or more covered employees to provide commuter transit benefits for their workers.
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What Happens to Unused Amounts in an Employee’s HRA When Their Employment Terminates?
September 22, 2022
When an employee who has a balance in their health reimbursement arrangement (HRA) terminates from the plan the employer is not permitted to “cash out” the HRA, but there are three ways employers may decide to handle this situation.
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ACA Deadline Changes and Elimination of Transitional Good Faith Relief
September 22, 2022
Earlier this year the proposed regulations updating deadlines and ending good faith relief for Affordable Care Act (ACA) reporting became law. Among other things, the regulations require that the deadline for furnishing IRS Forms 1095-C to employees will be March 2 (or March 3 in a leap year) – which is 30 days more than what was previously allowed; and the transitional “good faith relief” for employer ACA reporting would no longer apply to tax years after 2020.
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Health Savings Accounts as a Retirement Plan
September 22, 2022
There has been a focus on Health Savings Accounts (HSA) in recent years. This is a valuable vehicle that extends even beyond the "triple-tax-free" benefit that most employers are aware of. HSAs can reduce taxable income in retirement, which may affect Medicare premiums and the portion of Social Security benefits subject to federal income tax. There are many questions that revolve around HSAs and so we will attempt to address them here.
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Impact of the Inflation Reduction Act on Group Health Plans
September 22, 2022
President Biden has signed the Inflation Reduction Act. Employer-sponsored health plans are only indirectly impacted, but there are three main points to consider: the enhanced ACA premium tax credit, the reduction on Prescription Drug Prices for Medicare, and the expanded safe harbor for HDHPs.
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How to Manage Open Enrollment Mistakes
June 30, 2022
There are several things to take into consideration when an employee wants to make a change to their open enrollment elections. Has there been a life event? Have they truly made an error, or have they just changed their mind?
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What to Do With Unused Commuter Benefits Funds
June 30, 2022
With changes to workplace arrangements and working conditions following the COVID pandemic, employers are seeking ways to allow their employees to use already contributed commuter benefits funds, and to differentiate their welfare benefits package.
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Affordable Care Act (ACA): What You Need to Know
June 30, 2022
What do groups need to know to abide by the ACA? Three important questions determine whether your group falls under the “pay or play” mandates. Do we have to offer insurance? Who gets offered insurance coverage? What kind of coverage do we have to offer?
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IRS Announces Midyear Increase to Standard Mileage Rates
June 30, 2022
Normally the IRS adjusts the standard mileage rates at the beginning of each year, but occasionally they announce changes at other times to correspond with current costs.
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IRS Releases 2023 HSA Contribution & Coverage Limits
May 2, 2022
The IRS has issued Revenue Procedure 2022-24, providing inflation-adjusted Health Savings Account (HSA) contribution amounts for calendar year 2023.
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What to Consider When Choosing an HSA Beneficiary
March 30, 2022
Health Savings Account (HSA) owners can choose to name their spouse, adult children, other individuals, or a trust as their beneficiary. If no beneficiary is named, the HSA will be distributed to the estate. Careful consideration should be made when choosing a beneficiary as there are different tax implications depending on who is listed, or not listed, as the beneficiary of the HSA.
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Maintaining ACA Compliance When Hiring a Former Employee
March 30, 2022
There are many advantages to bringing back former employees, but applicable large employers need to follow the Affordable Care Act (ACA) rules when determining when to offer benefits. The key to this is determining whether the employee should be treated as a “new hire” or a “continuing employee.” This determination will tell the employer whether to offer benefits right away or if the designated waiting period applies.
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Enhance Your Benefit Offerings with a Post-Deductible HRA
March 30, 2022
During this time when unprecedented numbers of employees are changing jobs, employers need creative ways to enhance their benefits programs to increase employee satisfaction and attract new talent. Lowering the employee’s medical deductible by offering a post-deductible health reimbursement arrangement (HRA) is one way to do that.
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DOL Guidance for Over-the-Counter COVID-19 Tests
March 30, 2022
Group health plans and health insurance issuers must provide benefits for certain items and services related to testing for the detection and diagnosis of COVID-19, including over-the-counter (OTC) COVID-19 tests. Effective January 15, 2022, these services must be provided without imposing cost-sharing requirements, prior authorization, or other medical management requirements.
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From the Compliance Manager: Impact of the Continued COVID-19 National Emergency
March 30, 2022
As the United States anticipates the illusive end of the COVID-19 pandemic, there is cause to be continually mindful of ongoing regulatory guidance and changes. Although legislative activity including new laws and regulations is not near the level seen in the early months of the pandemic, it is important to understand what is temporary, what is renewed, and what is the new standard.
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PCORI Fee Update
March 30, 2022
In late December 2021, the IRS issued Notice 2022-04, providing the updated rate for Patient-Centered Outcomes Research Institute (“PCORI”) fees for plan years that end on or after October 1, 2021, and before October 1, 2022.
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Temporary Telehealth HSA Coverage Extended
March 16, 2022
On March 15, 2022, President Biden signed the Consolidated Appropriations Act, 2022. Included in the bill is a provision that temporarily reinstates health savings account relief, which allows high deductible health plans (HDHPs) to waive the deductible for telehealth and other remote care services, regardless of the plan year and without causing plan participants to lose HSA eligibility.
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Important Chard Snyder ARPA Update
December 13, 2021
After 12/31/2021, Chard Snyder will no longer be including ARPA supplemental forms with the General COBRA Election Notice. Effective 1/1/2022, it will be the Plan Sponsor’s responsibility to notify Chard Snyder in the event of a Qualifying Event for an eligible Qualified Beneficiary where ARPA paperwork should be included. As of 1/1/2022, this information will NOT be included for any Qualified Beneficiary unless directed by the Plan Sponsor.
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Year-end Deadlines & Considerations, Part 1 (Cafeteria Plans)
December 13, 2021
Employers sponsoring health and welfare plans have needed to respond to a myriad of legislative and regulatory changes throughout 2020 and 2021 arising from the COVID-19 pandemic and related laws and regulations. With the end of the year fast approaching, it is necessary to be aware of several important deadlines and considerations, and for employers to work with their claims administrators to take necessary actions.
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Year-end Deadlines & Considerations, Part 2 (COBRA)
December 13, 2021
As a result of the pandemic, the Department of Labor extended a number of deadlines for health and welfare plans. These extensions apply to participant claims and appeals deadlines, participant health plan special enrollment rights, and participant obligations under COBRA. Per applicable law, these deadlines could be extended for only up to one year. Plan sponsors should be mindful of whether deadlines are still tolled and should be prepared for the end of the deadline extension. Employers who have not yet amended their plans to reflect the deadline extensions for notices, elections, and certain other specific actions relating to COBRA and claims and appeals may consider setting forth how (and for how long) those extensions will apply.
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Considerations for Contributing to an HSA After 65
December 13, 2021
More than 10,000 Americans turn age 65 each day and the majority will enroll in Medicare. Those who are currently contributing to a health savings account (HSA) may unknowingly violate IRS guidelines by contributing to their HSA once covered by Medicare and end up owing fees and penalties. Employees can easily avoid this scenario, but only if they understand the rules and how to recalculate their HSA contribution limit for the year (and possibly the prior year as well).
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Lifestyle Spending Accounts: Not Your Basic Welfare Benefit
December 13, 2021
While adoption of tax-advantaged savings plans like Health Savings Accounts (HSAs) continues to rise, Lifestyle Spending Accounts (LSAs) are also gaining in popularity. Compliance for these employer-sponsored account-based offerings are relatively simple compared with other benefits such as HSAs, HRAs, and FSAs. An employer’s main considerations when offering an LSA includes taxation of the plan and avoiding the triggers for group health plans and other legal requirements.
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Eligibility Rules for Enrolling in Both an FSA & an HSA
December 13, 2021
Eligibility rules for tax-advantaged healthcare savings accounts can be confusing for employees, especially if their employer offers a high-deductible health plan (HDHP) and multiple savings account options. Let’s look at an example of a common situation and eligibility rules to maintain compliance.
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IRS Releases 2022 Qualified Benefit Plan Limits
November 10, 2021
The IRS has announced new contribution limits for 2022, including limits for flexible spending accounts, commuter benefits, and adoption assistance.
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IRS Issues Notice Regarding COBRA Premium Payment Deadlines
October 11, 2021
On October 6, 2021, the IRS issued Notice 2021-58, which clarifies emergency COBRA extensions enacted due to the COVID pandemic. Notice 2021-58 explains the application of the one-year extension to COBRA continuation coverage premium payments, election, and interaction with the subsidy available under the American Rescue Plan Act (“ARPA”).
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Who Can I Cover on My HSA?
August 26, 2021
Health Savings Accounts (HSAs) are a great way to save for future healthcare costs. You can make tax-free HSA contributions as long as you are covered under a qualified High Deductible Health Plan (HDHP). But whose care can you pay for with tax-free HSA money?
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Top 5 Compliance Priorities for 2022
August 26, 2021
In our current environment of the ongoing pandemic, a flurry of new laws and regulations, and social change, employers face unique challenges in health and wellness benefits management. Employers will be expected to show good-faith compliance, and therefore should consider these top five compliance-related priorities for planning 2022 health, leave, and fringe benefits.
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FSA Debit Card Substantiation Rules
August 26, 2021
In IRS Information Letter 2021-13, the agency recently reiterated the requirement that Flexible Spending Account (FSA) claims paid with a debit card include the required substantiation, containing all of the information normally required for a claim submitted for reimbursement through means such as an online portal or mobile app.
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Participant Claims Submission Update
August 26, 2021
In an effort to continually enhance our protection of plan participants’ private information, beginning October 15, 2021 Chard Snyder will no longer accept Savings & Spending Account claim submissions or debit card purchase supporting documentation via email. This change is to help ensure the security of our participants’ personal data. Our priority is the protection of our participants’ private personal and health-related data.
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Dependent Care Debate: Plan Savings or Tax Credit
August 26, 2021
Recent legislation has created much-needed flexibility for employers who offer dependent care assistance programs (DCAPs). At the same time, the dependent care tax credit was greatly expanded allowing individuals in 2021 to receive better tax advantages by using the tax credit than contributing to their employer-sponsored dependent care accounts. This raises the question whether employers should spend effort and planning to increase the DCAP plan limits to the maximum allowable by law.
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Health Savings Accounts (HSAs): The Basics
August 26, 2021
Health Savings Accounts (HSAs) are tax-advantaged savings accounts held by individuals to pay for eligible healthcare expenses covered under a High Deductible Health Plan (HDHP) until their deductible has been met. The IRS has strict guidelines regarding who is eligible to open and contribute to an HSA.
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Important Guidance on COBRA Premium Assistance & ARPA Expiration Notices
August 26, 2021
One of the final notices required to be sent by ARPA is to notify eligible COBRA participants that their subsidy will be ending and outline critical information following the subsidy expiration. These expiration notices are required to be sent to subsidy participants between 45-15 days before the subsidy ends.
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Pandemic Relief for Dependent Care Assistance Programs
June 21, 2021
Running a business is never easy. Although most employers are used to dealing with unexpected challenges, no one was prepared for what happened in 2020. The COVID-19 pandemic changed everything. With little warning, employers had to come up with an entirely new way of doing business. Some employers had to drastically reduce their employees’ hours or were forced to go out of business. Millions of individuals lost their jobs.
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Ask Penny: What happens to my FSA when I have a life event that changes my status, like a new baby?
June 21, 2021
Enrollment in health insurance and related benefit plans like Flexible Spending Accounts (FSA) typically occurs annually during your company’s open enrollment period. Outside of open enrollment, you can’t make changes to your coverage until the next open enrollment period unless you have a Qualifying Life Event (QLE).
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Preparing for the End of ARPA COBRA Subsidies
June 21, 2021
While much focus, to date, has been on implementing the American Rescue Plan Act of 2021 (ARPA), employers and plan administrators must now turn their attention to preparing the necessary notice to some Assistance Eligible Individuals (AEIs) concerning the expiration of any subsidies they have received.
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Health Savings Accounts and ARPA COBRA Subsidy Eligibility
June 21, 2021
Many Americans currently save money for healthcare expenses through a Health Savings Account (HSA) paired with an employer-sponsored high deductible health plan (HDHP). However, due to the pandemic, many employees have lost their employer-sponsored health coverage. This may impact their eligibility to contribute to an HSA.
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From the Compliance Manager: COVID Pandemic Relief and Related Legal Challenges
June 21, 2021
In the current environment of fast-changing laws and regulations impacting employer-sponsored benefits, it is increasingly necessary for employers to conduct a critical review of benefit plan changes that have been offered or mandated during the pandemic. Several key areas require focused attention and prompt proactive consideration to maintain plan compliance. Here are some important questions to ask:
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New FAQs on ARPA COBRA Premium Assistance
May 24, 2021 - Additional IRS Guidance Concerning Premium Assistance for COBRA Benefits
On May 18, 2021, the IRS issued Notice 2021-31, which provides FAQs for further guidance on the American Rescue Plan Act of 2021 (ARPA) that was signed on March 11, 2021.
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IRS Provides Guidance on Temporary Dependent Care Benefits Allowed Under CAA & ARPA
May 12, 2021
The IRS has issued Notice 2021-26 to answer questions related to Dependent Care Flexible Savings Accounts (DCFSA), specifically the interaction between the temporary extensions and carryovers allowed by the Consolidated Appropriations Act (CAA) and the increased maximum contribution amount allowed by the American Rescue Plan Act (ARPA).
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IRS Releases HSA Contribution Limits for 2022
May 12, 2021
The IRS has issued Revenue Procedure 2021-25, providing inflation-adjusted Health Savings Account (HSA) contribution amounts for calendar year 2022:
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DOL Issues Additional COBRA Premium Assistance Guidance Under ARPA
April 9, 2021
The American Rescue Plan Act of 2021 (ARPA), enacted on March 11, 2021, allows qualified beneficiaries to receive premium assistance if health coverage was lost because of involuntary termination of employment or a reduction in hours. This assistance is available for the coverage period beginning on April 1, 2021, and ending on September 30, 2021. Premium assistance is initially “advanced” by the plan sponsor or insurer and then recovered or reimbursed through a tax credit.
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IRS Confirms Delay of Tax Filing Deadline to Include HSA Contribution Extensions
March 30, 2021
The IRS has issued Notice 2021-21, officially delaying the April 15, 2021 federal income tax filing due date for individuals for the 2020 tax year to May 17, 2021. This delay is a result of the ongoing COVID-19 Emergency Declaration issued in March 2020. The due date is automatically postponed from April 15, 2021 to May 17, 2021; there is no need to file an extension to receive this relief.
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IRS Provides Guidance on PPE as Reimbursable Medical Expenses
March 30, 2021
The IRS has issued Announcement 2021-7, indicating that amounts paid for personal protective equipment (PPE)—such as masks, hand sanitizer, and sanitizing wipes—that are primarily used to prevent the spread of COVID-19, are treated as amounts paid for medical care under Internal Revenue Code Section 213(d). As a result, these items are now eligible to be paid or reimbursed under health flexible spending accounts (health FSAs), health reimbursement arrangements (HRAs), and health savings accounts (HSAs).
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American Rescue Plan Act Provides COBRA Subsidies & Dependent Care FSA Limit Increase
On March 11, 2021 President Biden signed the American Rescue Plan Act of 2021 (ARP), which provides financial relief to employers and employees affected by the COVID 19 pandemic. The legislation included several provisions affecting health benefits:
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Department of Labor (DOL) Issues Guidance on Extension of Disaster Relief & Benefits Time Frame Extensions
March 8, 2021 - On Friday, February 26, 2021, the Department of Labor (DOL) released EBSA Disaster Relief Notice 2021-01, which provides guidance on the duration of COVID-related relief and the National Emergency “Outbreak Period.”
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IRS Issues Guidance on Consolidated Appropriations Act (CAA) & Impacts on Healthcare & Dependent Care FSAs
February 26, 2021
The IRS has issued Notice 2021-15, providing additional guidance to the Consolidated Appropriations Act (CAA) enacted on December 27, 2020.
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COBRA & Workers’ Compensation
February 17, 2021
Must an employer maintain health insurance benefits for an injured employee who is out on Workers' Compensation leave? When can the employee be placed on COBRA? The interaction of Workers' Compensation, FMLA, and COBRA all come into play in answering these questions.
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New Patient-Centered Outcomes Research Institute (PCORI) Fee for Self-Insured Health Plans
February 17, 2021
The IRS has released Notice 2020-84, updating the amount of the Patient-Centered Outcomes Research Institute (PCORI) fee that self-insured health plans must pay for plan years ending on or after October 1, 2020, and before October 1, 2021. PCORI fees are due by July 31 of the year following the end of the plan year.
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Understanding Substantiation Requests for Benefit Card Transactions
February 17, 2021
Today, savings and spending plan participants can swipe their benefit card and funds are automatically deducted from their benefit account(s) for eligible expenses. The benefit card eliminates most out-of-pocket cash outlays and paperwork, as well as the need for reimbursement checks. Some FSA and HRA debit card transactions, however, may still require substantiation. These substantiation requests can be a real pain point for employers and plan participants, so here are some helpful details to provide clarity.
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COVID Outbreak Period & Benefit Time Frame Extensions May End Soon
February 17, 2021
As we get further into 2021, it is unclear when the COVID-19 national emergency ("Outbreak Period") will end. However, the temporary extension of certain benefits time frames can be no more than one year (ending at the latest on February 28, 2021). Health and benefits professionals and their advisors should be aware of the imminent end to the relief and start planning to rollback processes to regular time frames effective March 1, 2021.
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2021 Consolidated Appropriations Act (CAA) Effects on FSAs
February 17, 2021
The 2021 Consolidated Appropriations Act (CAA) was signed into law on December 27, 2020. Designed to provide economic relief for victims of the COVID-19 pandemic, the relief provided limited provisions that directly affect limited, health, and dependent care flexible spending accounts (FSAs). Employers have the option to take advantage of any of these non-mandatory provisions, as long as their plan is amended to do so.
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Ask Penny: Can I use my HSA or FSA to pay for COVID-related healthcare expenses?
February 17, 2021
The COVID-19 pandemic has economically impacted many families through small business closures and job layoffs. The price of treating COVID-related illness has also negatively affected many Americans. One positive is that those with a health savings account (HSA) or healthcare flexible spending account (FSA) may be able to use these funds to cover COVID-related medical expenses. Here are a few helpful FAQs.
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HSAs & Income Taxes: Preparing for 2021 Filing
February 17, 2021
January 2021 has already flown by, and a new year means preparing to file new tax returns. Owning a Health Savings Account (HSA) has tax implications, so here’s what HSA account holders, employers, and their advisors need to know to be ready for the upcoming tax season.
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Consolidated Appropriations Act FAQs on Health & Dependent Care FSAs
January 28, 2021
It has been a month since President Trump signed into law new economic relief called the Consolidated Appropriations Act (CAA) 2021. The relief contained provisions affecting Health FSAs and Dependent Care FSAs.
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Additional COVID-19 Relief Signed Into Law, Affecting Health & Dependent Care FSAs
On December 27, 2020, President Trump signed into law new economic relief called the Consolidated Appropriations Act 2021. Provisions in the relief directly affect healthcare and dependent care FSAs.
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Offering an Adoption Assistance Program
November 19, 2020
Each year in the United States, about 135,000 children join their forever families through adoption. However, adoption can be an expensive process. To create a family-friendly environment and maintain a competitive benefits package, employers can offer adoption assistance to their employees. Adoption benefits can be low cost and provide a high impact.
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Ask Penny: What happens to my unspent FSA funds at the end of the year?
November 19, 2020
Due to COVID-related interruptions in medical care this year, it’s likely been a struggle to maximize your FSA dollars. You can use FSA funds to pay for things like medical expenses, doctor visit copays, vision expenses, and prescriptions. But keep in mind that FSA dollars have an expiration date. If you don’t use your funds before the end of the year, you may lose them.
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Terminating COBRA Coverage During the COVID-19 Outbreak Period
November 19, 2020
COBRA administration is complex, especially with the passage of temporary changes due to the COVID-19 pandemic. Many employers have struggled with the practical problems created by the various timeframe extensions. A common question we are hearing is, “When can employers terminate COBRA coverage during the Outbreak Period?” Without clear guidance, the best approach is to look at how the employer treats COBRA beneficiaries during the non-pandemic election period, and during the late payment grace period.
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From the Compliance Manager: COVID-Related Plan Document Amendments
November 19, 2020
Chard Snyder continues to focus on compliance of the pre-tax benefits we administer with 2020 legislation and agency guidance. Chard Snyder will amend all relevant plan documents for the permanent changes related to the indexed carryover, OTC changes that remove the ACA prescription rules, and HSA deductible exceptions for plans that offer telehealth through their medical coverage. Plan amendments for these permanent changes necessitated by the CARES Act must be implemented in the 2020 plan year with a signed amendment in order to be effective to your current plan.
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Refunding Dependent Care Flexible Spending Accounts: What is Allowable?
November 19, 2020
With much yet to be determined regarding COVID-related temporary changes and pending legislation, there continue to be outstanding questions surrounding the use of dollars allocated to Dependent Care Flexible Spending Accounts (DCFSA). Employers and participants are left to wonder how to use remaining DCFSA funds allocated for 2019 or elected in 2020, and whether to elect or make contributions in the 2021 plan year. Here’s what we know.
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End of COVID-Related Timeframe Extensions Rapidly Approaching
November 19, 2020
Plan sponsors should be aware of the imminent end (February 28, 2021) to the relief provided under the IRS/DOL Joint Notice extending certain timeframes and start planning accordingly.
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IRS Releases 2021 Qualified Benefit Plan Limits
October 27, 2020
The IRS has announced new qualified benefit plan limits for 2021. You can also find these and historical qualified benefit plan limits in this handy reference guide.
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Ask Penny: When can I make mid-year Flexible Spending Account (FSA) contribution changes?
August 31, 2020
Earlier this year, the IRS provided increased flexibility allowing for mid-year changes to FSAs and other benefit plans due to the COVID-19 crisis. Previously, mid-year plan changes were only allowed following a qualifying life event such as marriage or the birth of a child. Now a qualifying event may not be necessary, but there is one caveat: FSA mid-year changes are only available if an employer allows them.
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Changing COBRA Administrators & Medical Carriers During COVID-19
August 31, 2020
Plan renewal season is upon us and we’re still in the COVID-19 Outbreak Period (OP). The federal government has expanded COBRA election opportunities and employers should understand these provisions, especially if they are changing COBRA administrators or medical carriers as part of their benefit plan renewal process.
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Dependent Care Flexible Spending Accounts: What Now?
August 31, 2020
Due to COVID-19, there has been a dramatic increase in work-from-home arrangements over the last five months. Employers now have increased flexibility to make changes to their Dependent Care Flexible Spending Account (DCFSA) programs and allow employees to spend down their prior plan year DCFSA accounts. Here are some options available to employers based on IRS Notice 2020-29 and additional guidance.
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From the Compliance Officer: Plan Document Amendment Survey
August 31, 2020
The year 2020 has thrown us all more than a few curve balls and surprises. The health benefits industry has not been immune, with many COVID-related legislative changes passed over the last five months impacting benefits. Some changes to benefit plans are now mandatory, while others are optional. To maintain plan compliance, Chard Snyder will conduct a survey of our Savings & Spending account clients to clarify what benefit plan revisions are mandatory and collect client preferences regarding optional changes.
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Health Savings Accounts & Medicare
August 31, 2020
As the population ages, a growing number of Americans will soon become eligible for Medicare. Those enrolled in a high-deductible health plan (HDHP) with a Health Savings Account (HSA) will have to choose between electing Medicare or continuing to contribute tax-free dollars to their HSA. Navigating current regulations and being aware of pending legislation is a must.
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PCORI Fees Increased
June 11, 2020
Employer Payments Due by July 31, 2020
A less-talked-about piece of the SECURE Act was the extension of PCORI fees to continue through plan years ending before October 2029. On June 8, 2020, the IRS announced an increase to the PCORI fee amount to be paid by plan sponsors with a plan year end date between October 1, 2019 and December 31, 2019.
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COVID-19 Resource Library
June 5, 2020
In response to questions we have received related to the benefit plans we administer, Chard Snyder has compiled these helpful resources to provide guidance for our partners. Answers include the most recent information shared by the U.S. government and its agencies regarding the impact of COVID-19 on these services.
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COVID-19 Relief for Employee Welfare Benefit Plans
May 21, 2020
During the last few months, the Department of Labor (DOL), Treasury Department, and Department of Health and Human Services (DHHS) have jointly issued multiple pieces of guidance intended to provide relief to those suffering economic hardships from the coronavirus pandemic.
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IRS Releases 2021 Contribution Limits for HSAs
May 21, 2020
The IRS has issued Revenue Procedure 2020-32, providing inflation-adjusted amounts for health savings accounts (HSAs) for calendar year 2021:
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COBRA FAQs Regarding IRS & DOL Deadline Extensions
May 13, 2020
Chard Snyder has created FAQs regarding COBRA deadline extensions for participants and health plan sponsors in response to a joint ruling issued by the DOL & IRS on April 28.
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IRS Guidance Provides Section 125 Cafeteria Plan Flexibility in Response to Coronavirus
May 13, 2020
The Internal Revenue Service has released two notices to allow temporary changes to section 125 cafeteria plans and provide additional flexibility to participants
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IRS and DOL Provide Relief from Certain Time Deadlines for Participants & Health Plan Sponsors
April 30, 2020
Recognizing the impact of the COVID-19 pandemic, the Department of Labor and the Department of the Treasury have issued Notice 2020-01, which extends certain time frames affecting a participant's right to elect continuation of group health coverage under COBRA, pay premiums for COBRA continuation coverage, submit claims for coverage, and dispute denials of claims for benefits. The guidance also extends the period of time that a group health plan sponsor or administrator has to provide a COBRA election notice.
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Employee Benefits Eligible as “Payroll” for Small Business Payroll Protection Program Loans
April 16, 2020
The federal Small Business Administration (SBA) has issued guidance (FAQs) on Payroll Protection Program (PPP) loans available to small businesses during the coronavirus pandemic. Businesses with no more than 500 employees can apply for these loans if certain conditions are met.
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Updated SIGIS List of HSA- and FSA-Eligible Over-the-Counter Expenses Released
April 16, 2020
The Coronavirus Aid, Relief and Economic Security Act (CARES Act) permanently reinstated coverage of over-the-counter (OTC) drugs and medicines as eligible for reimbursement from Health FSAs and HSAs without the need for a prescription. Menstrual care products may also now be purchased or reimbursed through these plans.
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Webinar with Q&A: COVID-19 and Its Impact on Health Plans, HSAs, and Cafeteria Plans
April 16, 2020
Watch Chard Snyder's webinar featuring Darcy Hitesman, an Employee Benefits Attorney, to learn about "COVID-19 and Its Impact on Health Plans, HSAs, and Cafeteria Plans."
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DOL Issues New Guidance on Families First Coronavirus Response Act (FFCRA)
March 30, 2020
On Friday, March 27, the U.S. Department of Labor (DOL) issued further guidance on the FFCRA, including the Emergency Paid Sick Leave Act and the Emergency Family and Medical Leave Expansion Act.
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Coronavirus Aid, Relief & Economic Security (CARES) Act
March 30, 2020
On Friday, March 27, 2020, President Trump signed into law the Coronavirus Aid, Relief and Economic Security (CARES) Act to aid businesses, workers, and the U.S. healthcare system in dealing with the coronavirus pandemic.
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Families First Coronavirus Response Act
March 25, 2020
The US Department of Labor has released new information regarding the Families First Coronavirus Response Act (FFCRA), including helpful FAQs and fact sheets for employers and employees.
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HSA Contribution Deadline Extended to July 15, 2020
March 25, 2020
The IRS updated their Filing & Payment Deadline FAQs, confirming that HSA (as well as IRA and certain retirement plan) contributions otherwise due by April 15, 2020, can be made as late as July 15, 2020.
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President Trump Signs Emergency FMLA Leave & Paid Sick Leave Act
On Wednesday, March 18, 2020, President Trump signed into law the Families First Coronavirus Response Act to provide initial relief to American workers in the wake of the coronavirus pandemic.
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IRS Provides Guidance on COVID-19 Testing Coverage, HSAs & Associated HDHPs
March 12, 2020
On Wednesday, March 11, the IRS issued Notice 2020-15 allowing HSA-qualified health plans to cover testing and treatment of the coronavirus.
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Ask Penny: What do I need to know about filing taxes if I have an HSA?
February 27, 2020
There's no "one-size-fits-all" when it comes to preparing taxes, but contributing to a Health Savings Account (HSA) won’t add much complexity to your tax situation. Tracking down the right forms is the best place to start.
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From the Compliance Manager: HIPAA Best Practices
February 27, 2020
In light of the security and privacy incidences we hear about in the news on a daily basis, it seems to be a good time to highlight HIPAA in this issue of Compliance Watch. It is more critical than it ever to take protection of data seriously, going beyond awareness to taking active measures.
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Medicare & COBRA Myth Busting
February 27, 2020
In the world of healthcare benefits, Medicare and COBRA are two types of coverage that are extensive in their regulations and complicated to understand. How do they work together? Here are a few common myths that are debunked or verified to help in benefit plan design.
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Options for Employers Handling Leftover FSA Funds
February 27, 2020
For employees, the main downside to a Flexible Spending Account (FSA) can be the “use-it-or-lose-it” rule. If an employee doesn’t incur enough qualified expenses to use all FSA funds, any leftover balance generally reverts back to the employer after the end of the year.
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Tips for Reducing FMLA Compliance Risk
February 27, 2020
The Family and Medical Leave Act (FMLA) has made a positive impact in the lives of many employees, but the overall process of administering FMLA is challenging for employers. FMLA provides 12 weeks of unpaid, job-protected leave during a 12-month period (eligible employees) for:
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SECURE Act Legislation Update
February 27, 2020
Some interesting developments recently took place in the world of cafeteria plans and ancillary benefits as the Further Consolidated Appropriations Act 2020 (FCAA) was signed into law by the President. This law, including the Setting Every Community Up for Retirement Enhancement (SECURE) Act, contained comprehensive retirement-related provisions, but also included some implications for health and welfare benefits.
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Ask Penny: Can I pay for transportation expenses with my FSA or HSA?
November 25, 2019
You likely have a primary care physician and hospital relatively close by, but there may be times when you need to travel outside your local area to see a specialist for diagnosis and/or treatment. Medically related travel expenses can add up quickly, and your healthcare FSA or HSA can be used for many of them. What's eligible?
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Wrap Documents: What You Need to Know
November 25, 2019
Large employers may have the resources to prepare custom plan documents and Summary Plan Descriptions (SPD) for each employee benefit plan they offer. Most smaller employers, however, lack the time, money and expertise to prepare these documents and keep them up-to-date. One simple and cost-effective solution is the wrap document.
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New Notification Requirements for California Flexible Spending Accounts
November 25, 2019
The state of California has enacted Assembly Bill No. 1554 (AB-1554) into law, which becomes effective January 1, 2020. The law imposes new notification requirements for California employers that sponsor a health flexible spending accounts (FSA). California employers must notify FSA plan participants of the “use it or lose it rule," using at least two different forms, before each plan year’s end.
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New Guidance Simplifies Affordability Determination for ICHRAs
November 25, 2019
The IRS has issued proposed regulations that provide additional guidance to employers intending to offer an Individual Coverage HRA (ICHRA) for 2020 and beyond. The guidance confirms and clarifies the safe harbor provisions that were initially outlined in IRS Notice 2018-88. The proposed regulations are meant to help employers determine whether their ICHRA is affordable, and clarify the ICHRA nondiscrimination testing requirements.
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House of Representative Committees Propose Significant Changes Impacting HSAs
November 25, 2019
Earlier this month, the U.S. House of Representatives Republican Study Committee (RSC) released a comprehensive proposal to address perceived weaknesses in Americans’ access to quality, affordable healthcare. The proposal includes changes intended to significantly expand the use of health savings accounts (HSAs).
On October 23, the House Ways and Means Committee passed three bipartisan healthcare bills that expand and improve the usage of health savings accounts (HSA), flexible spending accounts (FSA), and health reimbursement arrangements (HRA). The bills, which reflect employer recommendations for modernizing and enhancing rules, would make several updates to current law.
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From the Compliance Manager: Best Practices for Timely Claim Filing
November 25, 2019
During the third quarter, Chard Snyder processed a large volume of plan participant appeals regarding timely claim filing. Through investigation of each one of these appeals, a common theme surfaced that the employee was either never made aware or not sufficiently reminded of their filing deadlines and other terms of their benefits. Here are some best practices around claim filing that we feel could enhance your employees’ experience.
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Spotlight on Substantiation: Understanding Substantiation Requests for Benefit Card Transactions
August 27, 2019
Before healthcare benefit debit cards became available, flexible spending account (FSA) and health reimbursement arrangement (HRA) participants had to pay for their eligible expenses at the time of purchase, submit claim forms along with all receipts, and then wait for reimbursement to be processed.
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IRS Provides Guidance Creating Two New Health Reimbursement Arrangements (HRA)
August 27, 2019
The U.S. Departments of Health and Human Services, Treasury, and Labor have jointly issued final regulations that create two new types of HRAs—the Individual Coverage HRA (ICHRA) and the Excepted Benefit HRA (EBHRA). The final regulations, which are applicable to plan years on or after January 1, 2020, give employers and employees more options when purchasing health insurance and covering out-of-pocket expenses.
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House Passes Legislation to Repeal Cadillac Tax
August 27, 2019
In July 2019, the U.S. House of Representatives overwhelmingly passed the Middle Class Health Benefits Tax Repeal Act of 2019 (H.R. 748), which eliminates the so-called “Cadillac tax” element of the Patient Protection and Affordable Care Act, often referred to as the Affordable Care Act or ACA. The recent 419-6 vote in the House is an indication of broad bipartisan support to repeal the Cadillac tax.
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Health Savings Accounts: What’s an Eligible Expense?
August 27, 2019
A Health Savings Account (HSA) is a tax-advantaged personal savings account that is used in conjunction with a High Deductible Health Plan (HDHP) to pay for eligible medical expenses as well as deductibles, co-insurance, prescriptions, vision expenses, dental care and over-the-counter health products. An eligible expense is any healthcare expense approved by the IRS for reimbursement through an HSA.
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Ask Penny: Can I have two FSAs in one household?
August 27, 2019
It's not uncommon for there to be multiple FSA accounts in a single household if the adults in the home each have one through their employer. Since an FSA lets you apply tax-free dollars towards eligible medical expenses, it makes sense financially for everyone in the family to take advantage of the benefit. But understanding how to manage FSA accounts with different employers can be confusing.
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Amazon Accepting FSA/HSA Debit Cards for Eligible Healthcare Purchases
May 30, 2019
Amazon has announced that their customers can now pay for eligible out-of-pocket medical expenses with a flexible spending account (FSA) or health savings account (HSA) debit card. Customers can use their FSA or HSA card to purchase a wide range of eligible over-the-counter items, eliminating the need to pay out-of-pocket or submit receipts for reimbursement.
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PCORI Fees Due July 31, 2019
May 30, 2019
The next annual fee that sponsors of self-insured health plans must pay to fund the federal Patient-Centered Outcomes Research Institute (PCORI) is due July 31, 2019, using IRS Form 720. In addition to self-insured medical plans, health flexible spending accounts (health FSAs) and health reimbursement arrangements (HRAs) that fail to qualify as “excepted benefits” are required to pay the per-enrollee fee.
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Why You Can’t Afford to Take HIPAA Security Incidents Lightly
May 30, 2019
The Department of Health and Human Services (HHS) Office for Civil Rights (OCR) recently announced a record year for Health Insurance Portability and Accountability Act (HIPAA) enforcement activity in 2018. OCR collected $28.7 million in penalties for the year, which surpassed the previous annual record by over $5 million. While most penalties are assessed against providers, there are still lessons employers with health plans should learn.
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Ask Penny: What Happens to My HSA If I Turn 65 and Am Still Actively Employed?
May 30, 2019
When you reach age 65, there are a number of financial decisions you will face, including what to do with funds accumulated in your Health Savings Account (HSA). The entire HSA landscape changes once you hit 65. Keep these things in mind, especially if you're still working.
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When an Employee Assistance Program is Subject to COBRA
May 30, 2019
COBRA and Employee Assistance Program (EAP) compliance can be frustrating and complex. Certain elements must be present for an EAP to be considered a COBRA-covered benefit. Plan sponsors should take care in determining which plans are subject to COBRA and comply accordingly.
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Guidelines for Termination of Employment at the End of FMLA Leave
February 28, 2019
Navigating a complex leave law like FMLA and staying current with ever-changing regulations can be burdensome. Some situations are difficult to navigate and remain compliant, especially if the employee on leave can’t return to work as planned. When is it ok to terminate an employee at the end of FMLA leave?
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IRS Issues Guidance for Qualified Transportation Fringe Benefits
February 28, 2019
Qualified transportation fringe benefits allow employees and employers to use pre-tax dollars towards commuting expenses. The amount of pre-tax dollars allowable varies based on cost-of-living adjustments by the IRS. (The monthly maximum limit for 2019 is $265.) In general, these benefits are completely optional and employers are not required to offer them. However, some cities with high commuter populations (e.g. New York City, San Francisco, Washington, D.C.) have laws that make it mandatory for employers to offer the benefit.
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Ask Penny: How can I recover mistaken HSA contributions?
February 28, 2019
The IRS recently issued Information Letter 2018-0033, which expands the instances in which an employer can recoup HSA contributions it made on behalf of its employees. The letter confirms that where there is clear documentary evidence of an administrative or process error, the employer may request the return of the contributed amounts, with any correction making it as if the error had never occurred.
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2019 DOL Penalty Amounts for ERISA Violations
February 28, 2019
The Department of Labor (DOL) recently announced increased 2019 penalties for employee benefit plans under the Employee Retirement Income Security Act of 1974 (ERISA). The increases generally apply to penalties that involve employee benefit reporting and disclosure failures if the penalty is assessed after January 23, 2019 and if the violation occurred after November 2, 2015.
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2019 Health Plan Compliance Calendar
February 28, 2019
Employers must comply with certain filing and disclosure requirements each year in connection with their group health plans. This chart summarizes some of the key requirements and is designed to be used as a tool to help facilitate annual compliance.
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Avoiding Compliance Mistakes During Open Enrollment
November 27, 2018
Open enrollment is one of the busiest times of year for employee benefits professionals. It’s a stressful season that typically results in questions and complaints, and comes with a high potential for both employer and employee mistakes.
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Offering Telemedicine Services While Maintaining Health Savings Account (HSA) Eligibility
November 27, 2018
Telemedicine services allowing individuals to have a “virtual” visit with a board-certified doctor have grown in popularity. Visits are conducted via phone or video and doctors can review electronic health records to diagnose, treat and prescribe some medications. Although medical services are provided virtually rather than in person, a telemedicine visit is a “real” physician visit, not just preventative care or a helpline. An increasing number of employers are offering telemedicine benefits to their employees, either as a stand-alone benefit (such as Teladoc®) or as an embedded benefit offered by their health insurance carrier.
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Trump Administration’s Proposed Rule Expands Usability of HRAs
November 27, 2018
On October 23, 2018, the Internal Revenue Service, the Department of Labor and the Department of Health and Human Services released a proposed rule broadening the availability and use of health reimbursement arrangements (HRAs). The proposed rule comes in response to President Trump’s executive order from October 2017, which called for the expansion of employers’ ability to offer HRAs to their employees and allow HRAs to be used in conjunction with non-group coverage. The newly proposed rule would seek to “expand opportunities for working men and women and their families to access affordable, quality healthcare” through changes to regulations under various provisions of the Public Health Service Act (PHSA), the Employee Retirement Income Security Act (ERISA) and the Internal Revenue Code (IRC). The proposed effective date is for plans beginning on or after January 1, 2020.
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Continuing Employee Health Insurance Coverage During Leave or Extended Absence: What’s an Employer’s Obligation?
November 27, 2018
When employees take leave from work for an extended period due to injury, illness or another reason, employers may be unsure if they must continue providing health insurance during the absence. The answer depends upon the circumstances, including the reason for the employee’s absence, the terms of the health plan, the size of the employer, and the applicability of one or more federal laws including FMLA and COBRA.
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Ask Penny: Should I Contribute to My HSA or My 401(k) for Retirement Savings?
November 27, 2018
Open enrollment season is here and employees electing a high-deductible health plan (HDHP) with a health savings account (HSA) must decide how much to contribute to their HSA for 2019. What’s a good recommendation? Employees should prioritize their HSA ahead of their 401(k), maxing out their HSA contributions if possible. Here’s why:
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What is Considered a HIPAA Breach?
November 27, 2018
The HIPAA Breach Notification Rule requires HIPAA-covered entities and their business associates to notify patients and other parties following a breach of unsecured protected health information (PHI). Similar provisions implemented and enforced by the Federal Trade Commission (FTC) apply to vendors of personal health records and their third-party service providers.
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2018 DOL Penalty Amounts for ERISA Violations
September 12, 2018
The Department of Labor (DOL) announced increased 2018 penalties for employee benefit plans under the Employee Retirement Income Security Act of 1974 (ERISA). The increases generally apply to penalties that involve employee benefit reporting and disclosure failures if the penalty is assessed after January 2, 2018, and if the violation occurred after November 2, 2015. As a background, the 2015 Inflation Adjustment Act directs the DOL to annually adjust for inflation certain penalties for specified ERISA violations.
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Industry News: What is a Pharmacy Benefit Manager (PBM) Clawback Clause?
September 12, 2018
Last year, I noticed that a drug I used to pay less than $10 a month for suddenly became subject to a $10 copay when I purchased it at my normal pharmacy. I questioned the pharmacist, who said I needed to call my insurer to find out why the cost had gone up. However, when I read my pharmacy bag tag, I noticed that it was missing the “your insurance saved you $XX” line, which I have made a habit of noting through the years. I questioned the pharmacist again and received a quick, “Ma’am, you’re going to have to question your insurance company.”
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Ask Penny: How Should I Calculate My FSA Election for Next Year?
September 12, 2018
With the beginning of Open Enrollment season, it may be helpful for potential FSA enrollees to consider some key questions to assist them in accurately projecting their annual FSA or Limited FSA election for 2019.
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Navigating State Privacy & Data Protection Laws
September 12, 2018
According to the Department of Health and Human Services (HHS) Office of Civil Rights (OCR) Breach Reporting Portal, by the end of June the number of 2018 reported breaches had already surpassed the total of breaches reported in 2017. As of August 2018, 3.7 million individual records had been reported as compromised compared to the approximate 2.7 million in all of 2017. The causes for the increase in reported breaches cannot entirely be confirmed, but education on reporting requirements along with an emphasis on high-profile data breaches in the media are likely some of the reasons for the increase.
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IRS FAQs on Paid Family Leave Federal Tax Credit for Employers
May 17, 2018
The IRS has recently released answers to Frequently Asked Questions (FAQs) for employers who want to claim a business credit on wages paid to an employee (who earned up to $72,000 in 2017) on paid family and medical leave, who met certain conditions. The IRS has adopted Section 45S, also referred to as Employer Credit for Paid Family and Medical Leave. To claim the business credit, employers must have a written policy that meets certain requirements, including the following items:
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Ask Penny: What is the ERISA Appeal Process?
May 17, 2018
It’s what we call “appeal season” here at Chard Snyder. Most of the plans we administer have a deadline of March 31 to submit claims incurred during the previous calendar year.
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Industry News: Average Healthcare Premiums for 2017
May 17, 2018
As medical premiums continue to increase, it is important for employers to remain informed regarding healthcare industry trends and averages. This is especially important for highly competitive industries as employers struggle to maintain talent. Chard Snyder is sharing the United States Department of Labor’s (US DOL) latest statistics for your information.
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PCORI Fees Due July 31
May 17, 2018
To support research on healthcare plans, including Flexible Spending Accounts (FSA) and Health Reimbursement Arrangements (HRA) that are not excepted benefits, employers are required to file and pay applicable PCORI fees using IRS Form 720 by July 31, 2018 for plan years that ended January 1, 2017 through December 31, 2017.
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IRS Releases New HSA Contribution and Coverage Limits For 2019
May 17, 2018
The IRS has announced the following new Health Savings Account limits for 2019:
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IRS Restores 2018 Maximum Family HSA Contribution Limit to $6,900
May 17, 2018
Today, the IRS released Revenue Procedure 2018-27. The Treasury Department and the IRS have determined that it is in the best interest of sound and efficient tax administration to allow taxpayers to treat the $6,900 annual limitation originally published in Rev. Proc. 2017-37 as the 2018 inflation adjusted limitation on HSA contributions for eligible individuals with family coverage under an HDHP.
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IRS Releases Revised Cost-of-Living Adjustments Impacting HSA Contributions (& Other Benefits) in 2018
March 6, 2018
One of the provisions in the Tax Cuts and Jobs Bill enacted late last year was a change in the way the IRS was to calculate cost-of-living increases. Today, the IRS released Revenue Procedure 2018-18, which provides these new recalculated limitations.
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How the New S132 Tax Ruling Affects Employers
February 14, 2018
The Tax Cuts and Jobs Act, passed in December 2017, became effective on January 1, 2018.
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Deadline Extended to Provide Forms 1095-B and 1095-C
February 14, 2018
The IRS has issued Notice 2018-06, extending the deadline for employers to furnish Forms 1095-B and 1095-C to individuals for the 2017 tax year.
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Understanding Letter 226-J for Applicable Large Employers
February 14, 2018
Applicable Large Employers (ALEs) are starting to receive the first round of IRS Letter 226-J.
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HSA Accountholders Should Have Received Form 1099-SA by January 31, 2018
February 14, 2018
Banks are required to report information about Health Savings Account (HSA) distributions on IRS Form 1099-SA.
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Why are employees being asked for documentation after a substantiation feed has been established with the insurance carrier?
February 14, 2018
Are you hearing from your clients and/or employees that they still have to substantiate debit card purchases when a feed is provided by your dental carrier, pharmaceutical benefits manager and/or health insurance carrier?
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How to Determine an ERISA Plan Name, Plan Number & Plan Year
February 14, 2018
Employee welfare benefit plans are required to have their own identifying information, which includes a plan name, plan number and plan year.
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Employers Can’t Deduct Cost of Providing Qualified Transportation Benefits
February 14, 2018
The Tax Cuts and Jobs Act was signed into law on December 22, 2017. Included in the law is a change that affects employers providing qualified transportation benefits.
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How FSA Carryover Works with COBRA
October 20, 2017
In order for a Flexible Spending Account to be eligible for COBRA continuation, there must be a positive balance at the time the employee experiences the qualifying event.