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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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: 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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Heath Reform: 5 States Will Have Early Access to Online Functions of the Federally-Facilitated SHOP Marketplace

‘SHOP Early Access’ Available in Delaware, Illinois, New Jersey, Ohio, and Missouri Starting in late October, small employers, agents, and brokers in Delaware, Illinois, New Jersey, Ohio, and Missouri will be able to experience some of the key new online functions of the federally-facilitated Small Business Health Options Program (FF-SHOP), according to the U.S. Department of Health and Human Services. The online SHOP Marketplace is expected to be available nationwide on November 15, 2014. SHOP Early Access During the “SHOP Early Access,” small employers in the five selected states will be able to use HealthCare.gov to take several initial steps in the enrollment process, including: Establishing a Marketplace SHOP account; Assigning an agent or… 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: Broker Handling of Confidential Tax Information

Agent and Broker Handling of Federal Tax Information Federal Tax Information (FTI) is classified as confidential and may not be used or disclosed except as expressly authorized by the Internal Revenue Code, which may require written consent of a taxpayer in certain situations. As an agent or broker operating in an Individual Marketplace, it is possible that we may encounter FTI when assisting with eligibility appeals. If you are an agent or broker and also a tax return preparer or work closely (e.g., share an office) with a tax return preparer (even if a small number of clients) we are subject to the tax return preparer disclosure rules set forth… 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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What is Small Group Defined Contribution-Private Exchange Solution?

What is Small Group Defined Contribution-Private Exchange Solution? With health care reform now being implemented, many employers large and small will consider this arrangement to offer their employees a quality, flexible, easy to use  and competitive benefit package. Simply, the employer decides what dollar amount they will provide to each employee. The employee then uses that dollar amount as a “voucher” of sorts. With the voucher or credit in hand, each employee can choose a plan that best suits their needs from a menu of health plans.  In the past, small group employers had to juggle the challenge of affordability and providing a quality benefit that worked for their entire… Read More

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Amerihealth NJ: Effective Immediately Ending Spousal 2 Person Groups

We received this e-mail today without any further guidance.:   EFFECTIVE IMMEDIATELY: C-Corp Owner/Spouse orEmployee/Spouse groups no longer eligible for small group coverage. AmeriHealth New Jersey will no longer accept or renew Owner/Spouse or Employee/Spouse groups, including C Corporations. If you have any questions, please contact your AmeriHealth New Jersey broker representative. Click the link below to download the entire message.   Amerihealth 2 person groups notification  

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Dental Plans: United Concordia Will Now Offer one of the Country’s Largest Networks

United Concordia Will Now Offer one of the Country’s Largest Dental Networks   United Concordia, Dental Network of America®, LLC and DenteMax®, LLC have entered into a network sharing agreement to provide greater access and deeper discounts to our members and clients. This agreement will take effect for United Concordia for 2015 business.   Click here to read more…

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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: 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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Horizon: Changes to 2015 MOOP’s

Changes to Maximum Out-of-Pocket Limits Under the Affordable Care Act (ACA), all non-grandfathered group health plans regardless of size or funding arrangement, must comply with annual limits on out-of-pocket maximums for in-network covered services that are Essential Health Benefits (EHB)1. These out-of-pocket maximums are also known as a plan’s maximum out-of-pocket (MOOP). Click the link to download the full notice: Changes_to_MOOP_Limits Please contact your Total Benefit Solutions account manager at (215)355-2121 if you have any questions or concerns.

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