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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.