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New interim final GINA regulations affect wellness programs
The IRS, DOL, and DHHS jointly released interim final regulations on the Genetic Information Nondiscrimination Act recently. In this article we review the provisions of GINA and their impact on employee wellness programs.
Health care reform – Putting the pieces together
With the flood of legislative activity in Washington around health care reform, it can be challenging to make sense of what the major issues are for policymakers. In lieu of analyzing all the individual proposals out there, we highlight and review the major reform issues that Congress is reviewing.
Congress introduces health care reform legislation
With a new administration comes new promises surrounding health care reform. While the status of health reform proposals fluctuates almost daily right now, here we review The Patients’ Choice Act – the first significant reform bill, introduced by Republicans in both the House and Senate in late May.
Empowering employees to make informed health care plan decisions
As part of a growing trend to explore consumer-driven health plans, employers are increasingly asking employees to actively participate in their health care management. In this article, we discuss tools that empower employees to make more informed health plan decisions.
Maximizing the value of benefits in a recession
In light of current economic conditions, many employers have had to consider, or even implement cutbacks in the benefits offered to their employees. Not all reward changes have to be a negative. In this article, we look at ways in which employers can motivate their workforce without having to spend a lot of cash.
IRS issues further COBRA guidance
The recent COBRA expansion, enacted into law as part of the stimulus package, has raised many questions for employers. The IRS and DOL have provided a flurry of guidance to assist plan sponsors in implementing these changes. Recently, the IRS issued Notice 2009-27, providing further clarification around eligibility for the new COBRA subsidy. In this article, we review the guidance.
New enrollment, notice and disclosure obligations for group health plans
The Children's Health Insurance Program Reauthorization Act of 2009 recently became law and expands the State Children's Health Insurance Program. Under the new law, states are allowed to subsidize premiums for employer-provided group health coverage for eligible children and families. The Act introduces new enrollment rights, along with new notice and disclosure obligations for employers that maintain group health plans. In this article, we review the legislation and new requirements for employers.
Stimulus package providing COBRA expansion signed into law
One of the more notable benefits provisions of the American Recovery and Reinvestment Act of 2009 (the "stimulus package") was an expansion of the Consolidated Omnibus Budget Reconciliation Act (COBRA). Here we summarize the new COBRA provisions and their effect on employer-sponsored group health care plans.
Fat reduction in lean times
It’s no secret to anyone that health care costs are continuing their rapid increases. In the current economy many companies may view that wellness programs are an unnecessary expenditure. In this article, we discuss why that “expenditure” may really generate large savings.
DOL finalizes FMLA regulations
The DOL recently issued final regulations under FMLA. Since much of the guidance from the proposed regulations remains unchanged, in this article we’ll focus primarily on two issues – explaining the military family leave provisions from NDAA; and clarifying the ambiguity that has arisen from varying interpretations of FMLA by both administrators and the courts over the last 15 years.
Welfare plan tidbits
There has been a flurry of legislative activity related to health and welfare plans. In this article, we touch on a few recent developments, including strengthening of the Americans with Disabilities Act of 1990 (ADA), enhancements to the rules for qualified transportation benefits and special rights under their parents’ medical plans for college students on medically necessary leaves of absence.
The OPEB Challenge – Mapping a comprehensive strategy for public employers
This is a summary of The OPEB Challenge - Mapping a comprehensive strategy for public employers white paper prepared by members of the Strategic Investment Advisory Group of J.P. Morgan Asset Management and J.P. Morgan Compensation and Benefit Strategies, in conjunction with the National Conference on Public Employee Retirement Systems (NCPERS).
Human resources and the 2008 “Bailout Bill”
On October 3, President Bush signed into law the Emergency Economic Stabilization Act of 2008 (EESA), better known as the “Bailout Bill”. While the provisions intended to save certain troubled financial institutions got all the press, EESA had provisions in it that affect human resource programs especially those related to compensation and mental health. In this article, we focus on those human resource programs and the changes that EESA brings to them.
IRS releases guidance on health FSA distributions under the HEART Act
Earlier this year, the Heroes Earnings Assistance and Relief Tax Act (HEART Act) of 2008 became law. The HEART Act was designed to provide much-needed financial flexibility for our military. In its first guidance on the HEART Act, the IRS has released Notice 2008-82 which discusses Qualified Reservist Distributions (QRDs). QRDs provide certain military reservists with special options in their health care flexible spending accounts, but employer action is necessary to enable the process. This article explains the IRS guidance.
IRS releases proposed regulations under Internal Revenue Code (“Code”) sections 4980B, 4980D, 4980E and 4980G
On July 16, 2008, the IRS released proposed regulations under Code sections 4980B, 4980D, 4980E and 4980G pertaining to health savings accounts (HSAs). The proposed regulations provide guidance in the areas of tax reporting and paying, HSA contributions, and qualified HSA distributions. In this article, we review the proposed regulations with respect to Code sections 4980B, 4980D, 4980E and 4980G.
Further HSA guidance released
As health care costs continue to escalate, more and more employers are turning to health improvement programs in The IRS recently released Notice 2008-59. The notice provides guidance on health savings accounts in a number of areas, including contribution limits, eligibility, and administration and maintenance fees. The notice is provided in a question and answer format covering 42 items. The following article reviews those aspects of HSAs that are not covered in other guidance.
Health and wellness programs: a long-term perspective
As health care costs continue to escalate, more and more employers are turning to health improvement programs in search of lasting solutions. As the short-term benefits of health improvement programs become more widely accepted, it is also important to consider the likely long-term impact of these programs. In this article, we look at health improvement programs through a long-term perspective.
Treasury, IRS issue 2009 contribution limits for HSAs
On May 13, the U.S. Treasury Department and Internal Revenue Service IRS released Revenue Procedure 2008-29, which lists the new indexed amounts, adjusted for inflation, for HDHPs and HSAs. The following article lists the 2008 amounts and the new 2009 amounts.
DOL proposes new FMLA regulations
On February 12, the Department of Labor (DOL) proposed the first new regulations under the Family and Medical Leave Act of 1993 (FMLA) since 1995. In this article, we’ll discuss many of the key FMLA issues, trying to focus somewhat equally on what the proposed regulations tell us, what’s different in the proposed regulations, and what guidance is still needed.
Sixth circuit overturns district court ruling on vesting of retiree health benefits
On March 19, the Sixth Circuit Court of Appeals remanded Noe v. PolyOne Corp to the District Court for the Western District of Kentucky. In this article, we examine the case that centers on whether certain retiree health benefits vest and the District Court had granted summary judgment in favor of the defendants, PolyOne.
DOL provides further guidance on wellness programs
We highlight the DOL’s recently published checklist for wellness plans to be HIPAA-compliant.
R.I.P. Erie County decision
In this article, we’ll discuss the 3rd Circuit Court of Appeals’ Erie County decision (Erie County Retirees Association v County of Erie, 220 F.3d 193(3d Cir. 2000)), what it means with regard to medical plan designs (mostly retiree medical), and finally what the EEOC did in its final regulations to make moot the decision commonly referred to as Erie County.
America’s Health Crisis: Is Consumer Driven Health Care an Enabler or Antidote?
In this article, we examine consumer driven health care and its impact on employees and the traditional healthcare system.
…And Health Care for All
2008 Democratic presidential nominee, Senator Hillary Clinton (D-NY), drew the attention of journalists everywhere as she unveiled The American Health Choices Plan (AHCP). What would the senator’s health care plan mean for employers with another Clinton in the White House?
Questions from Readers March 2007
In this regular monthly feature, we provide answers to reader questions we think may have broader appeal and serve to enlighten our growing Insight community.
IRS, DOL and HHS Release Final HIPAA Regulations
On December 13, 2006, the IRS, EBSA, and HCFA published final nondiscrimination and wellness program regulations providing guidance on HIPAA compliance. Here we provide a comprehensive overview to these guidelines.
Overview: The Tax Relief and Health Care Act of 2006
In the last days of the 2006 "lame duck" session, Congress passed the Tax Relief and Health Care Act of 2006. Here we provide an overview of the changes in regards to Health Savings Accounts (HSAs) and other aspects of health care plans.
Further Clarification from DOL on HSA Administration
As employers have begun to implement HSAs, a number of questions have been raised regarding the administration of HSAs and compliance with the guidance provided in FAB 2004-01. Here we provide a summary of the issues.
Personal Health Records: What Employers Need to Consider
In the second of a two-part series on personal health records (PHRs) and electronic health records (EHRs), we discuss the implications and challenges faced by employers looking to offer PHRs.
PPA 2006 -- Health and Medical Benefits Provisions
The PPA contains various provisions that impact health and medical benefits. Here we review impacted areas including Section 420 transfers, bona fide association plans, contracts with a long-term care features and public safety officer plans.
Personal Health Records: A Primer
In the first of a two-part series on personal health records (PHRs) and electronic health records (EHR), we offer a primer on the information systems.
Retiree Drug Subsidy - Is CMS Getting the Right "Message"?
In this article, we take a closer look at the typical process involved for plan sponsors to calculate and report subsidy amounts, and we suggest ways to make the process a more judicious one for the rest of the year and beyond.
Engaging Key Stakeholders in Health Improvement Programs
The most effective health improvement programs aren't events but processes, designed to engage both employees and the CFO office.
New Proposed IRS Regulations on Dependent Care Expenses
Recently, the IRS released proposed regulations to update and clarify the expenses eligible for reimbursement under dependent care assistance programs (DCAPs) and dependent care income tax credit. In this article, we overview the highlights.
Medicare Part D Updated Disclosure Notices
On April 26, CMS released updated guidance for required disclosure notices sent to Part D eligible individuals. Here we overview the differences from the 2005 versions.
Medicare Part D PDP Option Boosts Subsidies and Reduces GASB Liability for Public Sector Employers
In 2007, we will likely see most public sector employers shift to one of the Medicare Part D PDP alternatives to take advantage of the reduced costs under the Medicare Modernization Act (MMA). Here we review the advantages.
Medicare Part D Employer Subsidy Checklist
Here we provide a checklist (along with relevant links to the CMS site) to assist employers opting to file for the Medicare Part D subsidy.
Changes to the Definition of Dependent
Technical corrections to the Working Families Tax Relief Act of 2004 treat more individuals as dependents for HSAs and dependent care plans. As a result, employers may need to reevaluate these programs.
Retiree Health Subsidies -- Key Element in Determining OPEB Charges
In this article, we review GASB's approach to recognizing a subsidy for retiree health benefits that are being "fully charged" to retirees.
Medicare Part D Update: Notification of Creditable Coverage Requirement
CMS now requires that all plans providing prescription drug coverage to Medicare eligible participants submit a notice of creditable or non-creditable coverage via an internet based form.
Common Employer Questions Regarding Medicare
In this special feature, we answer employers' frequently asked questions to clear up some of the confusion surrounding Medicare.
GASB 43 & 45: Accounting, Reporting and Disclosure Requirements for Government OPEBs
The new standards outlined in GASB 43 and 45 have the potential for tremendous increases in the expenses and liabilities reported in the financial statements of many government entities. Here we review these and other implications of the new standards.
Things Your Mother Never Told You About Health Savings Accounts (HSAs)
In this article, we review the complexities, advantages and disadvantages of HSAs so that employers and employees will have a complete picture.
Communication: Giving Employees the Opportunity to Make the Right Health Care Decisions
This article offers food for communication thought - lessons learned from rolling out significant changes within companies and information to help you produce the best possible strategy for communicating your health care and wellness programs.
HRAs or HSAs, How Does an Employer Decide?
To assist an employer in deciding between HRAs and HSAs, this article compares the important features of each in a question and answer format and then discusses their advantages and disadvantages.
Prescription Drug Coverage in Light of Consumerism Initiatives
Due to the rapidly rising cost of prescription drugs, which has outpaced all other components of healthcare over recent years, employers are evaluating various coverage options. Here we outline some important considerations.
Disease Management Outcomes Measurement: A Review of the Different Methodologies
While research indicates that disease management efforts result in cost savings, there is no standard methodology to measure their impact. Here we discuss outcomes measurement, commonly used methodologies and the strengths and weaknesses of each method.
Bona Fide Wellness Programs Under HIPAA
Proposed HIPAA regulations provide guidance to enable employer-sponsored wellness programs to reward healthy behaviors using financial incentives. In this article, we outline the features of a "bona fide wellness program" as defined by HIPAA guidelines.
Impact of ADA and ADEA on Wellness Program Design
In this article, the various design aspects of wellness programs are considered where potential problems with other statutes might arise. Because ADA, ADEA and OWBPA are potentially the most problematic, these legislations receive the primary focus.
Good Health Pays Off! The Fundamentals of Health Promotion Incentives
How do you get employees to focus on maintaining and improving their health rather than seeking treatment once they are sick? Here we discuss various employer wellness options and the pros and cons of each in reducing health care costs.
Communicating Regulation Changes to Employees and Retirees
Here we provide plan sponsors with a "top ten" checklist of steps to keep in mind when communicating regulatory changes. We also provide information and suggestions specific to Medicare Part D legislation.
HSA Guidebook Part 7: Distributions
The last of our seven-part HSA series takes a closer look at distributions from an HSA.
HSA Guidebook Part 6: Employer Involvement and Comparability Rules
The sixth of our seven-part HSA series takes a closer look at employer contributions and comparability rules.
Part D Update: Plan Sponsors Compete with Consumer PDP Campaigns
Upcoming marketing campaigns by PDPs will make Part D employee communcations more important than ever. This article discusses the confusion caused by these campaigns and a sample Q&A for educating participants.
HSA Guidebook Part 5: Trustees and Custodians
The fifth of our seven-part HSA series takes a closer look at trust and custodial accounts.
HSA Guidebook Part 4: Contributions to an HSA: Tax Treatment of Permissible Contributions
The fourth of our seven-part HSA series takes a closer look at the parts of an HSA that an employee can control.
HSA Guidebook Part 3: Employee Control of an HSA
The third of our seven-part HSA series takes a closer look at the tax treatment of permissable HSA contributions.
HSA Spotlight: Preventive Care Administrative Issues
HSAs are gaining momentum in the marketplace as a vehicle to get employees more engaged in decisions about their healthcare. Here we discuss how to qualify and what constitutes preventive care.
HSA Guidebook Part 2: The HDHP and Preventive Care
The second of our seven-part HSA series takes a closer look at High Deductible Health Plans (HDHPs) and Preventive Care.
HSA Guidebook Part 1: HSA Overview and Eligibility
The first in a seven-part series analyzing the ins and outs of Health Savings Accounts (HSAs), an increasingly popular consumer-driven health care option for employers.
Revised "Use-It-Or-Lose-It" Rule Q&A
Under Notice 2005-42, an employer may now amend the cafeteria plan document to allow a grace period of up to 2 1/2 months immediately following the end of each plan year to use amounts deferred in the previous plan year but remain unspent.
Considerations in Applying for the Medicare Part D Employer Subsidy
Although employers have various options to reduce their retiree benefit costs, Part D timing constraints have convinced most employers to apply for the federal subsidy (at least for 2006). Here we review how to qualify, apply and communicate this option.
Preparing for the Medicare Part D Employer Subsidy: Participants That Enroll in Both a PDP and the Employer's Plan
Many participants will be confused by Medicare Part D legislation. As a result, some of them may enroll in both the employer plan and a PDP. Here we discuss the financial risks of dual enrollment and how plan sponsors can prevent it.
IRS Modifies "Use-It-Or-Lose-It" Rule
The IRS recently released Notice 2005-42 which allows employers to provide a grace period to the previously rigid "Use-it-or-Lose-It" rules of Health Flexible Spending Accounts.
But, You Promised! Why the Future of Employer Provided Retiree Medical Coverage is Bleak
Employer-sponsored retiree medical coverage is a slowly vanishing species. This article reviews the reasons for the decline and the solutions that are currently being explored.
Playing the Annual Part D Employer Game
Medicare Part D regulations take effect in 2006. Here, readers can find key dates and priorities related to applying for the employer subsidy, as well as actuarial equivalence, coordination between plans, and retiree communications.
HIPAA Privacy Requirements and Health Care Flexible Spending Accounts: Have Smaller Employers Forgotten Something?
While group insured health plans may qualify as an exception to HIPAA safeguards, health care FSAs are not exempt from HIPAA administrative simplification requirements. As a result, many small employers may be noncompliant - and the penalties are steep.
Additional Guidance Released by CMS
Today, CMS issued additional guidance for employers or unions with retiree medical plans that cover prescription drugs.
How Are Wellness Benefits Taxed?
Since there are no specific Internal Revenue Code sections that apply to wellness benefits, this article explores how various wellness benefits are taxed.
Corporate Fitness Programs Create Healthier Employees
Although it's still early in the process, employer-sponsored health initiatives are beginning to show promising returns on investment.
Medicare Part D: Final Regulations
With the new regulations finalized, employers must start their preparations for 2006.
Medicare Part D: Preparation for 2006
With the new regulations finalized, employers must start their preparations for 2006.
Medicare Part D Legislation: Employer Options
This article weighs the various pros and cons of each of the employer options in response to Medicare Part D legislation.
Making Workplace Wellness Work: Instituting a Four-Pronged Approach
At CCA, we take a proactive approach towards preventive care by offering a comprehensive health improvement program for our employees that focuses on lifestyle modification and documented improvement.
Medicare Prescription Drug Improvement and Modernization Act
On August 3, CMS released the proposed regulations of the Medicare Prescription Drug Improvement and Modernization Act. We review employer options and outline some of the key regulations related to applying for the federal subsidy.
CCA Comments on the Medicare Prescription Drug Improvement and Modernization Act
The first draft of the proposed legislation has sparked a number of questions here at CCA. How will employers handle wrap around plans? How is the subsidy calculated? How should actuarial equivalence be determined? Are the proposed deadlines realistic?
New Health Savings Account Guidance Issued
The IRS recently released several pieces of guidance relating to the new "Health Savings Accounts" ("HSAs") that were introduced as part of last year's Medicare Prescription Drug Legislation.
Medicare Discount Drug Cards Coming Soon
Information and FAQ on the provisions of the new discount drug cards, which become effective June 1, 2004.