leevena

I looked at one of our groups, just under 3,000 contracts, had a 10% rebate figure, which is where I suspected it would be. We go back and forth on this, sometimes charging the group a fixed admin cost (such as $8 pepm) or charging nothing. We leave it up to the group.

Yes, we have groups doing it both ways. when you say insights, what are you looking for in particular?

Thanks for the reply. I was starting to worry I was wrong.

I always interpreted it as meaning that the employee had access to a computer, with email capabilities and an email address, because they needed to use that computer for work. Key here was the "need" for their job. As opposed to someone who may have access to a "community" computer at work.

What am I missing? The act allows for hra if the group meets the following; 1) group is under 50/not subject to ACA, and 2) does not offer health insurance to any of its employees. JRG's 2nd post indicates a group health plan is offered.

Isn't it the FSA Plan Doc that needs amending (with a revision of the SPD)?Sometimes, the Plan Doc is also the SPD, so maybe I'm stuck in semantics. You may. The spd is the key plan document. Anything else produced, such as schedules, etc. are plan documents too. But spd is always the key one.

We are getting all over the board here, feel like we need to focus. Original question had to do with what events allow for a change of status, specifically if a birth would result in a status change. The answer to this is yes. Next step is to review the spd to see if the employer allows for mid-year changes for a birth. According to jsb, it does. Next step is the carrier, as I and GMK state above, and see if the consistency rule is followed. Again, according to jsb post above, it appears to be met.

Chaz, I am not an expert on retiree coverage. Could you expand on your answer? Thanks

Sorry, should have been a little more clearer. Yes, it has to do with ACA, but I cannot say about state law. Only caution I would offer is about the 35 employees. ACA uses " full time equivalents" so it is possible that the group has over 100 fte's but only 35 currently insured.

Yes, thanks. Wonder why the site I went to was not as clear. What site did you use, I would like to bookmark it. Thanks again.

Don't doubt you, but can you explain the second sentence that states "you must USE the money within the plan year."

No offense, but I believe this may be incorrect. I am not a FSA expert, so I use the govt sites quite often for these types of questions. I have cut and pasted from Healthcare.gov FSA limits, grace periods, and carry-overs You can put up to $2,550 into an FSA each year. You generally must use that money within the plan year. But your employer may offer one of 2 options: •It can provide a "grace period" of up to 2 ½ extra months to use the money in your FSA. •It can allow you to carry over up to $500 per year to use in the following year. Your employer can offer either one of these options but not both. It’s not required to offer either one. Learn more about these FSA options. At the end of the year or grace period, you lose any money left over in your FSA. So it's important to plan carefully and not put more money in your FSA than you think you'll spend within a year on things like copayments, coinsurance, drugs, and other allowed health care costs.

Maybe they are making up for all the erroneous reports of Abe Vigoda deaths. Lol. Too soon?

What type of administrative services are you looking to provide? Oops, never mind, just saw retirement.

thank you gmk, did not know that.

Try Healthcare.gov website, search "preventive" I tried to cut and paste link but could not. Is this what you are looking for?

Flyboyjohn...yes I agree the carrier already knows, I could have been a little clearer. I said you provided the info because the employees were enrolled via your group health plan. Sorry for the confusion.

Instructions on distribution states that the carrier must provide a copy to the employee, not the employer. My guess is that since this is new, they may be cautious. Quick question, since you provided the info to the carrier, what questions could you not answer? By the way, I suggest telling employees to ask their tax advisor.

I agree with you, there is not requirement that a new plan notify that it just started.

Not enough info available. In a fully-insured program GBurns is correct, there is usually an episode of care process in place. (I say usually because I am not versed in all states regulations). In a self-funded program it depends on how the contracts are written (12/12, 12/15, run-in, etc.) as to who has the liability. In fact, it is possible that the employer could be left with the costs.

A waiver credit is still permissable under ACA. But there are at least 2 ACA issues that should be considered. The first issue is that the IRS has not issued any written guidance on the use of waiver credits. Some believe they will allow them to continue, others do not. The second is the impact these waivers may have on the affordability calculations. On this issue there has been verbal IRS guidance stating that the waiver value needs to be added to the affordability calculations, but no written. There are a few non-ACA issues such as participation requirements, overall plan costs, and probably a few more. As for #2, the size of the waiver, this is confusing and quite frankly I cannot imagine why the employer would do this. Are you sure of the number? I realize costs differ, but a yearly cost of $12,000 is closer to a single cost than a family cost, at least from what I have been seeing lately.

Difficult to answer your questions because I do not know enough about your current plan of benefits and funding arrangement. Be that as it may, there is a very good chance that your plan's cost did rise because of ACA. Student health plans historically have had benefits were not very great. Under ACA this is not allowed, so assuming your plan of benefits needed to be increased, it would follow that the costs were increased. As to the second plan option, i will assume that the plan meets all legal requirements. That being said, it is puzzling why the school would want to make it more difficult to enroll. Could be a situation of adverse selection, but without seeing more information I cannot answer with confidence. An HSA is a funding vehicle that belongs to the enrollee, not the school. They have no power over what the enrollee does or does not do with it. Again, without any more data/information I cannot give you a better answer. Hope this helps.

I agree with your assessment too, but I am not an expert. Everything I have read, on private and govt websites, refer to hours "worked" as the way to calculate fte. I cannot find a definition of hours worked that would include these payments. Good luck.

Sorry, I too am a little confused. Trying to understand exactly what is occuring with the second group. But regardless, the test for affordability will be if the employee cost exceeds 9.5% of the income used to calculate. The additional compensation provided by the employer will increase the income used for calculation. By way of an example, the coverage gross cost is $500 per month/$6000 per year, the employee comp is $30,000. Employee writes a check for $500 per month/$6000 per year and the employer increase the comp by $500 per month, to a total of $36,000 per year. If this is what you are describing? If so the test would be if the $500 per month/$6000 per year paid is 9.5% or below. At $36,000 per year the 9.5% threshold would be $3,420.

My question revolved around your post stating the use of "premiums" as a way to for the employee to fund the costs. If I as an employee use the on-site medical provider and am presented with a bill for services, those expenses are eligible to be reimbursed through my participation in a 125 medical expense plan. There is no difference between that medical provider and any other. However, if you are looking to use some form of a capitation to fund the clinic, I doubt very much if the IRS would view this as an eligible expense, because it is not a "premium" for them.