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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Plan cost inaccuracies found on HealthCare.gov

Consumers who have complex medical diagnoses that require specialty drugs should carefully examine the health insurance plans offered through the public exchange system to avoid incurring high costs for those drugs. But that task will be complicated by inaccuracies on the public exchange website. That’s the conclusion of an analysis of public exchange plans by Avalere Health. The study, in which researchers went through all available plans looking for “hidden” drug costs, found that silver plans in particular tend to place such drugs in specialty tiers in their 2015 formularies. Avalere said that 17 percent of silver plans contain two or more specialty drug tiers that will drive up out-of-pocket… Read More

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Total Benefits Introduces New Compliance and Health Reform Education Center

Total Benefits Comply is our new Compliance and Health Reform Education Center where we will keep a copy of our health care reform bulletins throughout the year, in an easy  to view format, along with short informative videos. This new resource makes it easier to quickly find the answers to your reform questions and download a short, to the point bulletin. At Total Benefit Solutions Inc., we are dedicated to providing the information and advice that our clients need to remain compliant and make informed healthcare decisions. If you have any further questions please contact you Total Benefit Solutions account manager  at (215)355-2121 Click here for Total Benefits Comply.

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HR 360: How to Calculate Pay or Play Penalties

HR 360: How to Calculate Pay or Play Penalties: Make sure you are ready for 2015 with our basic step-by-step guidance on calculating pay or play penalties. This attorney-reviewed guide, provided by our partner HR360,  makes it easy to understand how to calculate ACA penalties. HR360 is provided as a service to Total Benefit Solutions clients. If you have any additional questions regarding this bulletin, or the Affordable Care Act, please contact your Total Benefit Solutions account manager at (215)355-2121 Download How to Calculate Pay or Play Penalties    

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Additional requirements for 90-day waiting period

Additional requirements for 90-day waiting period   Group health plans and health insurance issuers cannot impose waiting periods greater than 90 days. This 90-day waiting period is effective for plan years beginning on or after January 1, 2014. It does not apply to HIPAA Excepted Benefits or retiree-only plans.   These regulations allow for a one-month orientation period to determine if the employee is eligible for health coverage. Once the employee is determined eligible, he or she must receive health benefits in no more than 90 days.   The start date of an eligible employee, marks the beginning of the one-month maximum orientation period. The orientation period is determined by… Read More

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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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Health Reform: Healthcare.Gov Sneak Preview

Healthcare.Gov Sneak Preview Announced Yesterday, Affordable Care Act customers can peek at 2015 prices for the program’s health plans today after the government released a “window-shopping” feature overnight Here is a direct link to the 2015 “sneak preview”: https://www.healthcare.gov/see-plans/ If you have any questions or concerns about your 2015 enrollment, please contact Total Benefit Solutions at (215)355-2121

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Total Benefit Solutions is your Marketplace Navigator

What do you get with Total Benefit Solutions as your Marketplace Navigator? A broker who is Unbiased and objective  Trained Local Certified Licensed Insured Up to date Representing you Part of a team of dedicated professionals Click here for more information and to see our “Marketplace Navigator” brochure: Individual Enrollment Navigator Brochure  

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2015 Health Reform: Prepare for Health Insurance Open Enrollment

Preparing for 2015 Open Enrollment Getting prepared for open enrollment 2015 has been a major challenge. Total Benefit Solutions is dedicated to serving all of our clients throughout this second annual open enrollment period. With that in mind our offices will be open on the weekend of November 15th 2014 to help you get enrolled. Open enrollment for individual plans begins November 15th, 2014 and ends February 15th 2015. Anyone who enrolls prior to the 15th of the month will be effective the 1st of the next month. This is important because you must enroll by December 15th in order for your plan to be effective on January 1st, 2015… Read More

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IBC: Individual customers will receive a communication to prepare for open enrollment this week

  From Independence Blue Cross & Amerihealth: Individual customers will receive a communication to prepare for open enrollment this week Independence Blue Cross (Independence) will be sending letters to individual customers to remind them about 2015 Open Enrollment dates, inform them how they can prepare now, and let them know we will send additional details in the coming weeks. Each letter will include a list of upcoming health insurance meetings they can attend, along with a card that will make it easier for them to keep track of their enrollment information. These letters will include the agent’s name and phone number, and encourage individuals to contact their agent with questions.… Read More

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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: Eligibility for the SHOP Marketplace

Eligibility Requirements for the SHOP Marketplaces In 2015, small businesses that offer coverage through the Federally-facilitated SHOP (FF-SHOP) may be able to offer employees a choice of QHPs and qualified dental plans (QDP) within a given metal level or issuer, or a single QHP or QDP. 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 employee on payroll Have 25 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 year). While the FF-SHOP must determine eligibility using the definitions above, State-based SHOP… 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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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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HR360: Employers Must Provide Exchange Notice at Time of Hiring

Employers are required to provide an Exchange Notice (also referred to as a “Notice of Coverage Options”) to each new employee at the time of hiring as of October 1, 2013. For 2014, the notice can be provided within 14 days of an employee’s start date. Click below to read the bulletin from HR360: HR360_notice at time of hiring   If you have any questions about the HR360 subscription, or exchange notices, please contact your Total Benefit Solutions account manager at (215)355-2121.    

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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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Health Reform: What is a Special Enrollment Period?

Special Enrollment Periods Under certain circumstances, individuals may enroll in a QHP or change QHPs outside of the annual open enrollment period. These SEPs are based on certain triggering events or special circumstances. Events that permit an SEP include: Gaining or becoming a dependent through marriage, birth, adoption, placement for adoption, or placement in foster care Gaining status as a citizen, national, or lawfully present individual Loss of coverage (e.g., loss of Medicaid eligibility, QHP no longer available), except if enrollment is terminated based on failure to pay premiums, fraud, or enrollee initiated termination Determination that an individual is newly eligible or ineligible for advance payments of the premium tax… Read More

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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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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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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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U.S. Supreme Court Contraceptive Ruling

In a 5-4 decision that was described by one of the dissenting Justices as a “decision of startling breadth”, the Supreme Court has ruled in Burwell v. Hobby Lobby Stores, Inc. that closely held for-profit corporations are not compelled to provide contraceptive coverage under the Affordable Care Act’s preventive care mandate if they object to that coverage on religious grounds. The decision is a “win” for Hobby Lobby who had challenged the contraceptive mandate saying it forced them to either violate their faith or pay fines.   Click here to download the bulletin

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SAME SEX MARRIAGE PA COURT DECISION

Prepared by Vince Phillips, PAHU Lobbyist May 22, 2014 On May 20, 2014, Federal Judge John Jones III issued a landmark ruling in Whitewood et al vs. Michael Wolf (Commonwealth of PA) that struck down Pennsylvania’s 1996 Marriage Law specifying that a marriage is defined as being between a man and a woman. The ruling also forced PA to recognize same-sex marriages conducted in other states. On May 21, Governor Corbett said that although as a Catholic, he disagreed with the ruling, he would not appeal it. The ruling is effective immediately but an unanswered question is effective date for employer-offered health plans. Is it now? Is it a month… Read More

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Comparative Effectiveness Fee Reminder

The Comparative Effectiveness Research Fee is now known as the Patient-Centered Outcomes Research Institute (PCORI) Fee. The Patient Protection and Affordable Care Act (the Act) imposes a new Patient-Centered Outcomes Research Institute (PCORI) fee, formerly the comparative effectiveness research fee, on plan sponsors and issuers of individual and group policies. The first year of the fee is $1 per covered life per year, the second year the fee adjusts to $2 per covered life and then it’s indexed to national health expenditures thereafter until it ends in 2019. Click here to download this bulleting regarding the timely payment of the fees.   Purpose of the Fee The assessed fees are to… Read More

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