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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.