HEALTHCARE REFORM ROADMAP

Requirement to Provide Notice of Health Insurance Exchanges Delayed

Posted on Fri, Jan 25, 2013

Great news for HR and Benefits professionals…the health insurance exchange reporting requirement for employers has been delayed indefinitely by federal regulators.  PPACA required employers to notify employees in writing by March 1 about the availability of public health insurance exchanges.  Since little is known about the actual functioning of exchanges and many of the administrative rules remain pending, the delay is a welcome relief for employers.

Read More

Topics: exchanges, health care reform

Reporting Health Insurance on W-2’s: Do the Requirements Add Up?

Posted on Fri, May 18, 2012

Read More

Topics: health care reform, reporting health insurance on W-2

"Play or Pay" Explained: Will You Be Fined Under Health Care Reform?

Posted on Mon, May 14, 2012

STEVE HOOK
Benefits Practice Leader

Read More

Topics: health care reform, play or pay, safe harbor

The Supreme Court’s Health Care Reform Decision

Posted on Mon, Apr 23, 2012

Well, the Supreme Court has decided the fate of the health care reform law. At least, it should have, according to its standard operating procedure. The Court usually takes a vote on its cases within days of the conclusion of oral arguments, which were held March 26-28. Although votes can be changed after that initial conference, it appears rare that a change affects the outcome of a case.

Read More

Topics: health care reform, oral arguments

The Silver Lining in Health Care Reform Debate

Posted on Tue, Apr 10, 2012

RENEE KUHS
Compliance Attorney

When my son was in fourth grade, I fondly remember helping him study for Social Studies.  As an attorney, I was not much help with Math homework [where calculators were prohibited] – but studying our three branches of government and the importance of the separation of powers was right up my alley.

Read More

Topics: health care reform

Health Care Reform Goes to the Supreme Court [As Cost Projections Double]

Posted on Mon, Apr 02, 2012

STEVE HOOK
Benefits Practice Leader

Last week was a busy one for the Supreme Court.  The court heard an unprecedented amount [3 days worth] of testimony to determine the fate of the President’s historic health care overhaul.

Read More

Topics: health care reform, individual mandate

Health Care Exchange Final Rules to Be Released [With More To Come]

Posted on Wed, Mar 21, 2012

STEVE HOOK
Benefits Practice Leader

Final rules on the health care exchanges created by the Affordable Care Act are expected to be released next week in the Federal Register.  This 600+ page document will set forth rules on: 

Read More

Topics: exchanges, health care reform, health care exchanges

Early Retiree Reimbursement Program Spends $5 Billion [Already!]

Posted on Thu, Mar 01, 2012

RENEE KUHS
Compliance Attorney

Read More

Topics: health care reform, Early Retiree Reimbursement Program

Summary of Benefits and Coverage Requirements Are Final

Posted on Wed, Feb 29, 2012

RENEE KUHS
Compliance Attorney

Process for implementing Health Care Reform

Read More

Topics: health care reform, summary of benefits and coverage

Health Plan Compliance: Can Your HRA Have Annual or Lifetime Limits?

Posted on Fri, Feb 03, 2012

RENEE KUHS
Compliance Attorney

Health Care Reform generally prohibits group health plans from imposing a lifetime or annual limit on essential health benefits.  Grandfathered health plans may impose “restricted annual limits” during plans years that begin prior to January 1, 2014.  Although it may have been an unintended result, Health Reimbursement Arrangements (HRAs) are also subject to the rules governing lifetime and annual limits. 

Health Reimbursement Arrangement Definition

An HRA is a self-funded medical reimbursement plan funded solely by employer contributions and not through salary reductions that:

1)    Reimburses some or all of the medical expenses of participating employees, spouses, and dependents up to a maximum dollar amount for a coverage period; and

2)    Allows participants to carry forward unused amounts remaining at the end of the coverage period for use later.

Exempt HRAs

HRAs that limit reimbursement to expenses related to dental or vision care are exempt from Health Care Reform.  Therefore, these HRAs are not subject to the lifetime and annual lifetime requirements.

Integrated HRAs

Recent guidance clarifies that where an HRA is integrated with other health coverage and that other coverage alone meets the requirements, the HRA is not also required to satisfy the lifetime and annual limit requirements.  To date, formal guidance on what it means for an HRA to be “integrated” has not been released. It is practical to treat an HRA that is offered to only to employees that are covered by the health plan as “integrated” until guidance is available.

Stand-Alone HRAs

Where an employer offers a stand-alone HRA, the HRA is subject to the lifetime and annual limit requirements.  Employers that sponsor a stand-alone HRA may request a temporary waiver as it applies to the HRA.  The Secretary of Health and Human Services (HHS) has the authority to grant a waiver where compliance with the lifetime or annual limit requirements would result in a significant decrease in access to benefits or a significant increase in premiums. 

HHS released guidance that recognizes that all HRAs set annual limits that are lower than the allowable “restricted annual limits” and that removing lifetime and annual limits from an HRA would result in a significant decrease in access to HRA benefits.  Therefore, HHS granted an automatic waiver to all stand-alone HRAs that were in existence as of September 23, 2010.  These plans will be deemed to comply with the waiver requirements for all plan years beginning prior to January 1, 2014.  Employers must continue to comply with the annual notice and record retention requirements. For further information on the process to obtain a temporary waiver from the lifetime and annual limit requirements please see Technical Instructions for the Waiver Extension and Waiver Application Process. 

HNI will continue to monitor legislative developments as Health Care Reform continues to evolve.   Employers are encouraged to design their health plan offerings in a way that keeps them in compliance with the rules surrounding HRAs.  

Read More

Topics: hra, health plan compliance