CEB

Self funded plans can determine the subsidy percentage based on dependent type. If you’re looking for savings, go after your RX plan first. Tons of opportunities there such as removing compound drugs except for kids. Preventing diabetes drugs for only diabetes or other FDA conditions. People are using them for weight loss and costing employers so much $$ for weight loss. Remove any drugs that are basically over the counter medications combined into a brand drug prescription (yes several of those allowed on employer plans). Consider adding speciality drug rebate program like Prudent RX. Join a collective RX group so your RX goes up to bid with 20 other companies rather than just your own. You’re buying at 100,000 lives rather than 2000 for example. Willis Towers Watson and Mercer both have them. Then decide if you want to make an employee pay the full cost of premiums for their spouse. Maybe instead have a spousal surcharge for working spouses that are on your plan but have access to their employer plan. And for child coverage why not do employee plus 1 child, employee plus 2 children, etc instead of one flat premium for all kids. Best of luck 🤞

Really appreciate your comments. I was thinking it would be associated with a HIPAA event as well.

Self Funded plans select the state for their plan. For example in Texas most employers select Utah for their because they are more relaxed. Self-Funded plans still have a state they have to operate under, you would need to understand that state rules like chaz was mentioning.

agree, the file could have been opened and that is putting their mistake on the recipient

Hello, can you provide me with some guidance on the "relaxed deadlines" in the "out-break period" when an employee fails to verify their dependents. The dependent was removed from the plan in May. But they are now providing documentation and asking for reinstatement. Under normal circumstances we do not allow the dependent to be re-enrolled until Open Enrollment.

I should probably mention this is not an outcome based program, just participation

My question is about the alternative wellness credit rule and how that impacts biometric screenings in remote work locations. We would like to use a national Lab to do our Biometric Screenings. Unfortunately, some of our job locations do not have a national retail lab nearby them. The national lab could send electronic interfaces that would allow wellness credits to be provided to employees without using to much of the benefit department staff. Are we required to provide an alternative solution for biometric screenings for remote work sites that would not have a national lab near them or could those employees be excluded, unless they are willing to drive several hours to a lab retail location, to avoid manual payroll credit entries. In other words, possibly avoiding giving credits for each employee doctors lab work with manual upload files for small town remote locations. At some point we would like to maybe do mail order kits, but not right now.

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Is the maximum limit for high deductible plans a combo of in and out of network or can the limit be for each type of structure? We have a shared family deductible and then individual out of pocket limits. This year we are thinking about adding an out of network structure and the costs in the network would not be credited towards the out of network limit.

Opinion only....You should only enter the amount that was distributed from the HSA for qualified medical expenses $1899.08. You wouldn't enter $2,100 unless the HSA actually distributed the amount from that account. The amount entered should be $1899.08 in my opinion. It is checking to see if there was a distribution that possible took place that should be taxed such as spending $20 on groceries included in the $1899.08. In that case you would say $1879.08 for qualified medical expenses, the system will then know to apply tax on the $20 paid from the HSA. If your child had a massive amount of medical expenses there is a different section that you would work through for a deduction, but most people wont be able to use that section unless they don't have insurance or they have a high deductible and/or OOP plan. I am not an accountant, but I use a tax filing software and the software looking to determine if any of the distribution should be taxable.

Hello, For retirees living abroad, may their international or government provided health insurance premiums and insurance out of pocket expenses be reimbursed by an USA HRA (former employer lumpsum awarded at retirement for medical expenses)? I would think no to other government premium insurance cost, but yes to private international medical polices and OOP. ? Carrie

Well in some states we claim sales tax on our IRS annual filing (standard or itemized), so this is going to get interesting for possible double dipping if people itemize every sales receipt they have for the year and also claim it on the HSA not thinking about the reimbursement from two sources.

Anyone else get a pretty large number of errors related to SSN & Employee name match for the 1094 reporting? It is really strange that IRS would reject employees Name/SSN that were not exactly the way it is on their Social Security card. So someone like Samuel Smith should have been Samuel Michael Smith on 1095. I don't recall anything saying that an employee needs to have their exact name in any employer system to be the same on their SSN card. So a abbreviated middle name may not be possible in the future because it causes errors or even the suffix like Jr. or II, etc could even be another problem. How are you approaching this problem if you received the errors back that SSN and Name do not match their records. How are you going to collect the data from the employees? A simple response would be I9 (unless employee provided passport/DL instead), but for so many errors, it will take a very long time to fix.

The plan language states employee can have working spouse as a dependent in plan because the plan was originally set up as EE+1 or 2 or 3 etc. coverage, but new plan rates are EE+Sp or EE+family.

Can an employee cover their working spouse, at the same employer, as a dependent in their health plan? Both are eligible for benefits. I thought it might be some kind of irs pretax problem. I just saw this when someone tried to elect family coverage but their spouse (open enrollment) is being added to their coverage and spouse is dropping their individual coverage.

Thanks

This is good information, thank you.

I heard the goverment actually released guidance that full time students and children not going to school (over 19) must pay the same premium rate.

Does anyone have a link with information about this new program and how employers can collect and submit premiums to the goverment for employees that will be enrolling in this program? I didn't have much luck on Google.

Are we able to require dependents over age 19 to be full-time students for dental coverage after September? I have seen some language from HIPAA stating that we need to treat dependents over 19 as any other individual (similar situation individual) under the benefit plans. However, I think benefit plans is just referring to health coverage, correct?

Just a couple of quick questions about a few of the reform laws that go into effect after 9/23/10. 1) Could an employer decide not to subsidies a portion of the employees health premiums if the employee is covering a dependent that is no longer a full time student or a dependent that is full time student but married? Or would the cost have to be the same for full time students and adult children not attending school? Would it be ok to have employee + family coverage premium where the employer subidizes X% of the premium and than charge a second premium (such as the full cost of the individuals premium) if the dependent is not a student or a married full-time student. 2) When does the medical loss ratio test go into effect? And does it impact medium to large employer self-insured plans? Or is this just for fully insured plans? I couldn't find that answer on google

I have been hearing about companies that have two different health plans based on service. A new hire goes into one plan for the first year and on their anniversary they move into a more generous medical plan. Do any of you have clients or does your plan work this way? I was wondering what the pros/cons are for this type of plan structure? Also, do you have any clients that have employees on a generous (aka media called "cadillac plan") but have dependents on a less generous plan? Is that even possible to have dependents on a plan with a higher deductible. If so, what would be the pros/cons? Thank you

Several ERISA attorneys have told me over the years that the IRS only allows changes to an FSA midyear if there is a "change in status" for the family. If a family member has a child they can add money, if there child graduates, they can decrease their FSA. Other types of health and welfare plans (other than FSA) could have an open enrollment if there are major changes to the plan that impact the members expenses. Many employers have FSA on a calendar year and have a different health plan year. I would recommend for your client to have open enrollment for the plan at the normal time in July or whatever plan year, but for their benefits to run on a calendar year (such as deductible/OOP) start over in January. That way things are a little more in balance.

Employment contract? If the individual is retired, they are not employed. How can the company be bound to provider medical coverage if the individual is no longer working? If you are offering retiree medical, than you need to expand your definition of eligibility and the terms to be eligible for retiree medical (such as age and years of service). You will than have an official legacy issue with your accounting department to determine long term cost to provider retiree coverage and if and when these individual loose coverage and if and when they can add or drop coverage. You also have to decide if you have one or two SPDS active and or retiree plan. Whatever happened to retirement packages? Such as giving a person a lump sum payment of 2 weeks (example only) of pay for every year they worked or something like that in which they could apply towards paying their cobra or other employer insurance premiums. You need a lawyer to get you out of this