Search

Search form

Monique WarrenBlog Posts

See all

More Guidance on the Summary of Benefits and Coverage (But No Surprises)

The Department of Labor, Health and Human Services and the Treasury collectively published new FAQs regarding the requirement to provide a summary of benefits and coverage (SBC) under the Affordable Care Act (ACA) (http://www.dol.gov/ebsa/faqs/faq-aca14.html#footnotes). The FAQs include an updated SBC template and an updated sample completed SBC (available at cciio.cms.gov and www.dol.gov/ebsa/healthreform).  It is noteworthy … Continue reading More Guidance on the Summary of Benefits and Coverage (But No Surprises)
April 27, 2013

Proposed Regulations on Certificates of Creditable Coverage

Proposed regulations published on March 21, 2013 addressed not only the 90-day waiting period rule discussed below but also the eventual elimination of notices of creditable coverage under HIPAA’s preexisting condition exclusions rules. The 2010 health care reform law prohibits group health plans from imposing preexisting condition exclusions, effective for plan years beginning on or … Continue reading Proposed Regulations on Certificates of Creditable Coverage
March 25, 2013

Proposed Regulations Released on the 90-day Waiting Period Rule

Eighty-nine pages of proposed regulations confirm that employers may not impose a group health plan waiting period of more than 90 days. No surprise there – the prohibition already was set forth in the 2010 health care reform law. A waiting period that provides for coverage to start on the first day of the month following 90 … Continue reading Proposed Regulations Released on the 90-day Waiting Period Rule
March 19, 2013

Health Care Reform – Minimum Value Calculator Available

Last week, the Department of Health and Human Services (“HHS”) and Internal Revenue Service (“IRS”) released a minimum value calculator to determine whether the percentage of the total allowed costs of benefits provided under a group health plan is at least 60% – a requirement in order for the employer plan to be treated as … Continue reading Health Care Reform – Minimum Value Calculator Available
February 24, 2013

Government Proposes Expanded Relief From Contraceptive Mandate

As explained in an earlier post, the 2010 health care reform law requires health plans to provide women’s preventive care and services without cost sharing. Regulations issued August 1, 2011 included all FDA-approved contraception for women in the definition of women’s preventive care and services. That includes abortion and abortifacient drugs (like the so-called “morning-after” pill). The regulations … Continue reading Government Proposes Expanded Relief From Contraceptive Mandate
February 4, 2013

Employer Relief – Extension for Issuing Health Care Reform Exchange Coverage Notice

As expected, the government issued guidance (in the form of frequently asked questions posted on the Department of Labor’s website) postponing the due date for employers to issue notices regarding the availability of health coverage under state exchanges. Under the 2010 health care reform law, a provision added to the Fair Labor Standards Act requires … Continue reading Employer Relief – Extension for Issuing Health Care Reform Exchange Coverage Notice
January 31, 2013

IRS Releases Proposed Regulations on Employer Penalty under Health Care Reform Law

The IRS released proposed regulations last week that amplify and modify earlier guidance issued on the 2010 health care reform law’s employer penalty provision.  Highlights of the proposed regulations include: For purposes of determining whether an employer has the threshold 50 full-time employees, an employer can use any consecutive 6-month period in 2013, instead of … Continue reading IRS Releases Proposed Regulations on Employer Penalty under Health Care Reform Law
January 3, 2013

IRS Updates Correction Procedures for Employer-Sponsored Retirement Plans

The Internal Revenue Service issued updated correction procedures for employer-sponsored retirement plans on New Years’ Eve. Revenue Procedure 2013-12 updates the Employee Plans Compliance Resolution System (“EPCRS”) previously set forth in Revenue Procedure 2008-50.  Now, nonprofit employers sponsoring 403(b) plans can correct document failures with the IRS’s blessing. A 403(b) plan document failure can be corrected … Continue reading IRS Updates Correction Procedures for Employer-Sponsored Retirement Plans
January 2, 2013

More Health Care Reform Fees – Redistribution of Risk

Employers wrestling with how to budget for the additional costs associated with the 2010 health care reform law have one more cost to consider: the “transitional reinsurance program” fee. Barely discussed in the public forum up to now (probably because the amount per plan was not determinable), the government has clarified how this fee could impact … Continue reading More Health Care Reform Fees – Redistribution of Risk
December 12, 2012

How Employers Can Approach Health Care Reform’s Shared Responsibility Penalty

Many employers put off making plans to deal with the employer shared responsibility penalty provision of the 2010 health care reform law until after the November elections.  With President Obama’s re-election and no real possibility of legislative repeal, procrastinating further would be ill-advised.  Employers need to understand now the way the penalty can be triggered … Continue reading How Employers Can Approach Health Care Reform’s Shared Responsibility Penalty
December 5, 2012

Pages