2014 Compliance Bulletin Compilation

Download our 2014 Compliance Bulletin Compilation, featuring all of our released compliance bulletins for the entire year!  Topics include, Health Savings Accounts, The Individual Mandate, Employer “pay or play” mandate, exemptions, FSA carryovers and much, much more. All of the bulletins are in an easy to search format for your convenience. 2014 Compliance Compilation – Download As always please contact your Total Benefit Solutions account manager at (215)355-02121 if you have any further questions or concerns.

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IBC: Effective January 1, 2015, HIPAA Certificates of Creditable Coverage are no longer required

On February 24, 2014, the United States Departments of Health and Human Services issued a final rule that addressed the requirement to provide HIPAA Certificates of Creditable Coverage (HIPAA Certificates) under the Affordable Care Act (ACA). As the ACA prohibits pre-existing condition exclusions, the new rule eliminates the requirement to provide HIPAA Certificates beginning December 31, 2014. What does this mean for members?  Previously, when coverage was terminated for a member or his/her dependents, Independence Blue Cross (Independence) issued a HIPAA Certificate. Because the ACA prohibits the application of pre-existing condition exclusions, which applies to both grandfathered and non-grandfathered health plans, these certificates are no longer required. Effective January, 1,… Read More

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IBC: Important information about member outreach for IRS reporting

From Independence Blue Cross: As you may know, the Affordable Care Act (ACA) requires all health insurers to report certain information about health care coverage to the Internal Revenue Service (IRS) for individuals with fully insured commercial health plans. This information includes an individual’s Tax Identification Number, which is typically the Social Security Number (SSN). The purpose of the IRS reporting is to help ensure that Americans have minimum essential coverage as required by the ACA. This is commonly referred to as the individual mandate. Independence Blue Cross (Independence) has determined that we do not have SSNs on file for some of your customers’ employees and/or their covered dependents. The… Read More

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Total Benefit Solutions Introduces New Individual Health Plan Private Exchange

Total Benefit Solutions is proud to announce that our newest development, in partnership with RX health is now available. Our new site, the Total Benefit Solutions Exchange can help consumers compare, choose and enroll on a new health insurance plan either on the healthcare marketplace or off. It can help find your subsidy, secure it and get enrolled!   https://totalbenefits.rxhealthinsurance.com/Shopping/14/1/     Log on today, get enrolled and stay legal!

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Health Reform: Guidance Issued-Employer Reimbursement of Individual Policies

  Previously, the Departments of Labor (“DOL”), Health and Human Services (“HHS”) and the Treasury (collectively, the “Departments”) explained that  HRAs and employer payment plans cannot reimburse individual policies. On November 6, the Departments issued their twenty-second set of FAQs which make clear that: An employer cannot offer employees cash to reimburse the purchase of an individual policy, without regard to whether the employer treats the money as pre-tax or post-tax to the employee. Such arrangements are subject to the market reform provisions of the Affordable Care Act (“ACA”), including prohibition on annual limits and the requirement to provide certain preventive services without cost sharing with which it cannot comply. Such… Read More

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IRS Derails Use of MV Plans Without Hospitalization

As you may know, in order to avoid penalties under the Affordable Care Act (“ACA”), large employers must offer their full-time employees coverage that is affordable and meets minimum value (“MV”). Some vendors exclude certain core benefits, such as in-patient hospitalization and/or physician services from their plans (referred to as “Narrow MVPs”) and use the MV Calculator to determine that the Narrow MVPs meet MV under the ACA. The vendors claim the Narrow MVPs insulate employers from penalty exposure and preclude employees from accessing subsidies in the Marketplace. There has been much controversy as to whether the Narrow MVPs do, in fact, satisfy the MV requirement. On November 4, 2014,… Read More

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2015 Medicare Part B premiums and deductibles to remain the same as last two years

Premiums, copays and deductibles for other Medicare programs for 2015 also announced  Secretary of Health and Human Services Sylvia Burwell announced today that next year’s standard Medicare Part B monthly premium and deductible will remain the same as the last two years. Medicare Part B covers physicians’ services, outpatient hospital services, certain home health services, durable medical equipment, and other items.  For the approximately 49 million Americans enrolled in Medicare Part B, premiums and deductibles will remain unchanged in 2015 at $104.90 and $147, respectively. This leaves more of seniors’ cost of living adjustment from Social Security in their pockets.

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IRS Coordinates Cafeteria Plan Rules with the ACA:Two New Election Changes Allowed

Two New Election Changes Allowed Existing cafeteria plan rules make it difficult (if not impossible) for participants to revoke pre-tax salary reduction elections mid-year and enroll in qualified health plan coverage through the Health Insurance Marketplace (the “Marketplace,” sometimes referred to as the “Exchange”).  To provide additional flexibility, the IRS issued Notice 2014-55, creating new opportunities for a participant to change mid-year an otherwise irrevocable cafeteria plan election. Click here to Download the Entire Bulletin      

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Health Reform: CMS finalizes auto-enrollment process for current Marketplace consumers

CMS finalizes auto-enrollment process for current Marketplace consumers CMS finalized its policy regarding how current Health Insurance Marketplace individual customers will renew their plans in 2015. Individuals who do not make an active 2015 plan selection will be auto-enrolled in the same plan with the same premium tax credit and other financial assistance, if applicable, as the 2014 plan year. Individuals are encouraged to return to the Marketplace to determine their current and accurate 2015 premium tax credit or cost-share reduction financial assistance.   Click here to read the entire release.   As always if you have any questions, concerns or need assistance enrolling, contact your Total Benefit Solutions ACA… Read More

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Health Reform: Guaranteed Renewability

Guaranteed Issue and Guaranteed Renewability The Affordable Care Act requires health insurance issuers to offer all of their individual market and group market plans to any applicant in the state. It also requires health insurance issuers to accept any individual who applies for those policies, as long as the applicant agrees to the terms and conditions of the policy, including the payment of premiums. This provision is called “guaranteed issue.” Coverage offered through and outside the Marketplaces may restrict guaranteed issue coverage to certain enrollment periods. Additionally, the Affordable Care Act requires health insurance issuers to offer to renew or continue in force coverage at the option of the policyholder. This… Read More

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Medicare Part D: Reminder to Distribute Creditable Coverage Notice

 Medicare Part D: Reminder to Distribute Creditable Coverage Notice    Employers who sponsor a group health plan with prescription drug benefits are required to notify their Medicare-eligible participants and beneficiaries as   to whether the drug coverage provided under the plan is “creditable” or “non-creditable.” This notification must be provided prior to October 15th each year. Please click the link below to read the detailed bulletin. Medicare Part D Reminder-091914R    

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Health Reform: Small Business Health Care Tax Credit

Small Business Health Care Tax Credit Many small businesses are eligible for the Small Business Health Care Tax Credit to assist with the cost of health insurance coverage. To qualify, businesses must: Have an average of fewer than 25 FTE employees (based on a 40 hour work week and excluding owners, owners’ family members, and seasonal employees) Have average annual employee wages below $50,000 (augmented to reflect cost-of-living adjustments (COLA) as of 2014) (business owner salaries are not included in this calculation) Pay a uniform percentage or amount (at least 50%) of the cost of single coverage of each employee’s health insurance The tax credit is generally available only for… Read More

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Health Reform: Network Adequacy Standards

Health Reform: Network Adequacy Standards For QHP certification, a plan must have an adequate provider network available to its enrollees. A QHP must: Offer a network with a sufficient number of providers, including mental health and substance abuse providers, to ensure access to all services without unreasonable delay Include a sufficient number and geographic distribution of essential community providers to ensure reasonable and timely access to care for low-income and medically under-served populations in the QHP’s service area   The Marketplaces offer only health insurance plans that are certified as qualified health plans, or QHPs. These QHPs must be licensed and meet certain transparency requirements. To become certified, a QHP… Read More

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Health Reform: Certain Affordable Care Act Provisions Will No Longer Apply to U.S. Territories

The Department of Health and Human Services (HHS) notified U.S. territories (Puerto Rico, the U.S. Virgin Islands, Guam, American Samoa and the Northern Mariana Islands) that the following Affordable Care Act provisions will no longer apply to insured plans sitused in the territories. Please click the link below to read the entire bulletin. Certain ACA Provisions Will No Longer Apply to U.S. Territories-082614R If you have any further questions please contact your Total Benefit Solutions account manager at (215)355-2121.

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Health Reform: Treatment of Interns for Employer Penalty Purposes

  If large employers do not offer affordable, minimum value coverage to all “full-time employees” they can be penalized beginning in 2015.  A full-time employee (“FTE”) is an employee under the common law standard who works on average at least 30 hours per week, determined monthly.  Under the common law standard, an employment relationship exists when the person for whom the services are performed has the right to control and direct the individual who performs the services, not only as to the result to be accomplished by the work, but also as to the details and means by which that result is accomplished.  Under this standard, an employment relationship exists… Read More

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Health Reform: SHOP Marketplace Changes for 2015

Health Reform: SHOP Marketplace Changes for 2015 In 2014, small businesses that offer coverage through an FF-SHOP Marketplace are able to offer their employees a single qualified health plan (QHP). In 2015, small businesses that offer coverage through an FF-SHOP Marketplace may be able to offer their employees a choice of QHPs and qualified dental plans (QDPs). To qualify for an FF-SHOP, a business must: Be located in an FF-SHOP’s service area (generally a state) Have at least one eligible common-law employee on payroll Have 50 or fewer full-time equivalent (FTE) employees on payroll This methodology includes part-time employees, but not seasonal employees (those working fewer than 120 days per… Read More

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Medicare Update: Medicare is no longer prevented from recognizing same-sex marriages

Medicare is no longer prevented from recognizing same-sex marriages Special Update: As a result of the June 2013 U.S. Supreme Court ruling invalidating part of the Defense of Marriage Act (DOMA), which denied federal benefits to legally married same-sex couples,Medicare is no longer prevented from recognizing same-sex marriages for determining entitlement to, or eligibility for, Medicare. The Social Security Administration is now processing requests for Medicare Part A and Part B Special Enrollment Periods, as well as reductions in late enrollment penalties, for certain eligible individuals in same-sex marriages.  Click here for more information.

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Health Reform: ACA Checklist for 2015/2106

Health Reform: Affordable Care Act Business/Plan Sponsor Checklist for 2015/2106   This bulletin features a checklist, including descriptions of key topics, to guide you through Affordable Care Act compliance in 2015-2016. Click the link to download the ACA Checklist: ACA Checklist for 2015-2016-082214R Should you have any questions, please contact your Total Benefit Solutions Inc., account manager directly at (215)355-2121.

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Health Reform: 2015 Annual Open Enrollment Period

Annual Open Enrollment & Effective Dates The annual open enrollment period (AEP) for 2015 begins on November 15th 2014 and ends on February 14th 2015. The open enrollment period is the time when you can change, or purchase a new qualified health plan (QHP) on a guaranteed enrollment basis. You do not need a special election period, or a life change event to enroll during the annual open enrollment period. The chart below illustrates the effective dates for enrollments taken during the annual open enrollment period.             Effective Dates for 2015 Annual Open Enrollment Period

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Health Reform: Individual Responsibility Changes for 2015

Individual Shared Responsibility Payment Amounts for 2014 and 2015 Tax Years The amount of the individual shared responsibility payment increases between 2014 and 2015. 2014: The annual individual shared responsibility payment is the greater of 1% of the taxpayer’s household income that is above the tax return filing threshold for the taxpayer’s filing status, or The taxpayer’s flat dollar amount, which is $95 per adult and $47.50 per child, limited to a family maximum of $285. However the total payment amount is capped at the cost of the national average premium for a Bronze level health plan available through the Marketplaces in 2014. 2015: The annual individual responsibility payment is… Read More

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FMLA Proposed Rules To Recognize Same Sex Regardless of Residency

FMLA Proposed Rules To Recognize Same Sex Regardless of Residency  The DOL is proposing to amend the regulatory definition of  “spouse” under the Family and Medical Leave Act (“FMLA”) so that “spouse” for purposes of FMLA rights would include a same-sex spouse, regardless of where the employee  and spouse live. This means the “place of celebration” will determine whether an individual is a spouse under FMLA, rather than the current rule which uses the “state of residence,” which recognizes a spouse under the law of the  state in which the couple resides. Click the link to download the bulletin: 070714-P-ERC-FMLA_Proposed_Rules (1) Please contact you Total Benefit Solutions account manager at (215)355-2121 if… Read More

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IRS: Further Guidance on Employer Payment Plans

New Guidance on Employer Payment Plans The IRS issued an FAQ addressing the potential consequences of an arrangement where an employer reimburses employees for the purchase of individual health insurance premiums on a tax-favored basis (referred to as an “employer payment plan”). For this purpose, individual health insurance premiums includes individual coverage purchased either inside or outside of the Health Insurance Marketplace. The FAQ follows up on earlier guidance describing these types of arrangements (Notice 2013-54). Click the link for more information: 060214_P_ERC_Employer_Payment_Plans (1)

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Total Benefit Solutions to partner with ThinkHR

        In another effort to enhance our client experience and bring value to our small business clients, Total Benefit Solutions is proud to announce that we have entered into an agreement to provide Think       HR. Soon our clients will get an introductory e-mail with instructions on how to access their complimentary ThinkHR account. We expect to have this resource available to our clients in September 2014, just in time for this year’s open enrollment period!   Think HR will help our clients: Stay up to date with the latest news and resources Remain compliant with best practices from HR professionals Build tools like job… Read More

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Exchange Notification Reminder

Exchange Notification Reminder  The very busy renewal date of December 1, 2014, is fast approaching. This notice is to remind you that each employer group must give their employees a Marketplace (Exchange) notification.       The first link below is for employer groups that currently do offer coverage. The second link below is for an employer that does NOT offer coverage to employees.  Please remember this notification is for the states of Pennsylvania and New Jersey. The form also works for any employer who is based in an FFM (Federal Facilitated Marketplace) State. It is NOT compliant in NY, MD or any other state that provides their own State… Read More

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What is HR360?

What is HR360? HR360 is the premier online human resources library that features the most current federal and state laws for health care reform, COBRA, FMLA, and hiring and terminating employees. Clients of Total Benefit Solutions have HR360 as a complimentary resource. Watch this short video below and ask us today for your free trial membership, or how your organization can benefit from using Total Benefit Solutions Inc., and HR360. Call us for more information at 1(800)924-6718.

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