leevena
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Everything posted by leevena
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Employer funding of HSA
leevena replied to John Feldt ERPA CPC QPA's topic in Health Savings Accounts (HSAs)
Once paid, it belongs to the pastor. If dies, passes along as any other asset. -
Employer funding of HSA
leevena replied to John Feldt ERPA CPC QPA's topic in Health Savings Accounts (HSAs)
2013 contributions are $3,100 individual and $6,250 family. The church can contribute in a variety of ways, pay as you go via paycheck, pre-fund, or look back. Does this answer your question? -
A couple of things. 1. I did not bother to read your links, too long. You may want to give us a head's up by stating what page/paragraph, etc. 2. Don't rely on non-govt sites, while they are usually correct, they are not definitive. I always use the govt site, such as DOL in this case. Per your question, waiting period cannot be counted. So based on your example, there is only 15 days without coverage. here is wha the dol site says. Generally, a significant break in coverage is a period of 63 consecutive days during which you have no creditable coverage. In some states, the period is longer if your plan coverage is provided through an insurance policy or HMO. Days in a waiting period during which you had no other health coverage cannot be counted toward determining a significant break in coverage. Your links are: http://www.dol.gov/elaws/ebsa/health/gloss...eak_in_Coverage http://www.dol.gov/elaws/ebsa/health/gloss...=Waiting_Period have a good day. Lee
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Your a day late. Try this discussion. http://benefitslink.com/boards/index.php?s...c=48673&hl=
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A couple of things. First, the employer will not be penalized because the employee has not opened an HSA account. Second, you should notifiy the employee, in writing, of this situation. In the letter provide timelines for the employee to follow to open the HSA account, including wording that after a certain time period, they will not receive the HSA contribution for that plan year. Any contributions that would have been made will be held until such time that the employee opens the account. If the employee does not notifiy you that they have complied, by the date in the letter, you do not need to contribute for that plan year. You can find the details and samples at Treasury website. Good luck.
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Need of a Limited-Purpose FSA with an HSA
leevena replied to a topic in Health Savings Accounts (HSAs)
Your thoughts/conclusions are essentially on mark. A couple of thoughts. 1. 2013 HSA contributions are limited to $3250 and $6,450. If I want to save even more money (as you suggested) and I have maxed out elsewhere, I would try to put my "medical reimbursement dollars" in the fsa so that I don't have to touch the hsa dollars. For example, if I believe I will have $1,000 of expenses (dental and vision), I would fund that in the fsa and allow the $3250 to remain there growing. 2. The limited fsa covers dental/vision, so if your benefits do not include those coverages this would be a good way to pre-fund and use tax-free. Also, and I know this can be cumbersome and complicated for some people, but most times it is better for an employee to fund their dental/vision via a fsa than via insured plans. My wife wears glasses and it is actually cheaper for us to go a provider as private pay then to pay premiums. Same with dental, we have found that dentists will discount their charges considerable if we offer to pay cash. So when I consider how much premium I pay, and the max of $1000 or $1500 per year I get, this works out better for us. 3. Your comment about state government and lack of disposable income, while it is generally accurate, I think you would be surprised to find out how easy it is for an average income to take advantage of this strategy. Not to say that it is rampant, but by the time some people hit their 50's, kids out of the house, big expenses have come and gone, a few extra hundred dollars a month appear and it could easily land in the "savings" pool somewhere. No arguments from me, you have essentially understood the issue, just some thoughts. Good luck -
HRA claims incurred by participant prior to death
leevena replied to a topic in Other Kinds of Welfare Benefit Plans
Yes, the HRA can pay claims for this situation. I was a little confused as to what made you hesitant. Was it the information in the "discussion" part under #3. Handling of an HRA upon the paticipants death? That discussion was about providing a death benefit. -
If your policy, and documents, state that the employee must be full-time and work 40 hours a week, then that is what you must follow. Since this person has never worked 40 hours, they are not eligible. You may want to check your policy/documents, many are now written at 32 hours per week.
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Yes, here is a link for you. http://www.dol.gov/dol/topic/health-plans/...information.htm
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There are ways you can offer these people coverage, but much of it depends on what is available in your market. A few, and I mean a very few, carriers will allow you to write these people, but they usually require that you give them the regular group business on the true employees. A second way is to find or create a program using individual polices in combination with the high risk pool available in your market. A third way is to see if there is any association business that they qualified for, such as a real estate or small employer. These are going the way of the dinosaur, but you may have one hanging around. Good luck.
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Linking HSA eligibility and HDHP enrollment
leevena replied to French's topic in Health Savings Accounts (HSAs)
I do not believe I have ever seen a requirement such as this. I would be curious to know the reason why you make it so. If an employee wants to enroll in a HDHP and not use an HSA, why would the employer care? If anything, the employee is costing the employer less. -
105(h) Nondiscrimination Tests
leevena replied to Chaz's topic in Other Kinds of Welfare Benefit Plans
As I mentioned earlier, the regulation requires that the benefits be the same. They are not the same. Hence my question. (My example is a hypothetical that I made up on the spot. For sake of discussion, let's assume that the HCIs have one more option than non-HCIs. Still no problem?) I agree to a certain point. Since the difference is a small difference with the deductibles and the non-hci's have access to an even better plan of benefits, there does not appear to be a problem, which is why I said "highly doubtful" in my repsonse. But the only way to know for sure is to have the govt review and pass judgement. -
105(h) Nondiscrimination Tests
leevena replied to Chaz's topic in Other Kinds of Welfare Benefit Plans
Other than a slight difference in deductible amounts in the one ppo (400 vs 500) it appears that benefits are the same and the non-HCI's have an additional benefit ($0 copay) that is not available to the HCI...am I missing something? It is highly doubtful that this employer would have a problem. -
There is no legal requirement that requires the employer to obtain it. It does make sense to collect it, either by a seperate form or throught an enrollment/waiver form with an additional statment/check-box.
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105(h) Nondiscrimination Tests
leevena replied to Chaz's topic in Other Kinds of Welfare Benefit Plans
Is this a trick question? 105 allows an employer to offer multiple plans but the issue is focused around benefit levels, contribution and eligibility. It appears that each group has access to the same, or very similar, benefit levels, except that the non-HCI actually have an additional PPO option and the HCI have an HMO option. It is rare that the HMO would be self-funded, so assuming the HMO is fully-insured, that plan would be excluded from the calculations. My guess is that this is ok. -
Health Insurance Reimbursement
leevena replied to Spencer's topic in Miscellaneous Kinds of Benefits
I am a little confused. There are 6 total, 4 are covered by their spouses plan and 2 pay for themselves. The employer wants to give $100 a month to the 2 employees who are paying for themselves, not the 4 who are on the spouse plans. So the confusion is, all 6 are paying for coverage of some sort, correct? That said, the employer can pay the two and not the other 4 by giving the 2 a raise. It appears that this employer believes in open communication and group sharing becasue all of them are aware of what he is considering. So if the employer does end up giving the 2 a pay raise my guess would be the other 4 will know about it and become upset. Open communication and sharing...don't beleive the hype! -
The original question does not provide enough specific details to give a qualifed answer, so please keep this in mind when reading. The definition of a POP is tied to the type of expense that is being sheltered, and in this situation it would be any eligible premiums that the law allows and does not include any of the flexible (dep care or unreimbursed medical) benefits. A few years ago the IRS made non-discrimination testing for POP plans easier by only requiring the eligibility portion of testing and eliminated the need for the contribution/benefits and concentration testing. So, if all employees can participate, and if they can all elect the same salary reductions for the same benefits, the plan meets the test. I was unaware of whether the incluse of a premium reimbusement account was all that controversial, sorry. Why? Hope this helps.
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We do option 2. It is very similar to what you state in your post; we purchase, maintain and pay just like it was a personal only phone. Company provides a fixed amount for phone and a fixed amount for data plan. If I spend less, they reimburse me what I spent. If I spend more, it comes out of my pocket. Every month I submit expense report and copy of bill. Hope this answers your question.
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Sounds like the owner is a wack job, a real life Captain Queeg. As for what they should do, I agree with Erisatoolkit to a point. Personally, I would tell the idiot to go pound salt in Utah. Additionally, you may want to look for employement elsewhere. Do you really want to work for someone like this?
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Change from HMO - Still Grandfathered?
leevena replied to a topic in Other Kinds of Welfare Benefit Plans
I generally don't provide "I don't know" answers, but no one has replied. I cannot put my finger on this one, but something smells fishy and I have two concerns, but no real definitive answer for you. Sorry. First, does the introduction of a PPO OON feature now constitute a significant OOP issue? I don't believe it does, but cannot be sure. The second, and more concerning to me is the transfer rule issues. The law is trying to prevent an employer from transferring enrollment to another plan for reasons that will benefit the employer and to some extent hurt the employees. When you say they are going to a HMO-like plan, it appears to me that they are going from a HMO contract to an EPO contract. As a side note, if this group is fully insured, or if you are keeping a high level of benefits (what is usually associated with HMO coverage) your efforts at value based plan design may be fruitless. I don't know the particulars (group size, funding vehicle, plan design, risk profile of the group, etc.) but it may be worthwhile to investigate giving up grandfather status to achieve the greate good of value based design. Sorry I could not give you a specific yes/no. Good luck. -
Filing a Complaint
leevena replied to karen1027's topic in Health Plans (Including ACA, COBRA, HIPAA)
So, you crucify her for her reading error "I cannot believe that you read it and still ask this question", yet part of your original answer was ( I have always seen it resolved through the state dept of insurance ) also in error! -
Filing a Complaint
leevena replied to karen1027's topic in Health Plans (Including ACA, COBRA, HIPAA)
The DOL does not have oversight on all benefit plans, so you will need to be more specific. Can you include information about the specifics of the complaint, the type of health plan you are/were enrolled in, and anything else you can think of. -
Health & Welfare Plans - Resources
leevena replied to TPApril's topic in Other Kinds of Welfare Benefit Plans
Start with the govt; DOL, IRS, HHS, etc. Each of them will allow you to sign up for alerts. You may want to find some private sources, such as law firms, consultants, or schools that send out articlesp, such as Colgate Law school, benefitslink.com, Passion for subro etc. The other thing I would suggest is when you read an article that was of interest, go to the author's site and see if they have an alerts signup. Over time you should be able to find what you need. -
HSA contributions - HCE is only 1 with family
leevena replied to Spencer's topic in Health Savings Accounts (HSAs)
Based on what you have outlined, the employer is ok because the contribution is available to all other employees. If there is a 125 plan being used, you will need to test for that. As for the contribution amount, I would suggest they determine a specified dollar amount, not a "100% of deductible" amount. Remember, there could be employees who have an non-employer sponsored hdhp and regulations require that the employer also contribute to that persons' plan. What if that person's hdhp has a different deductible, opening the employer to more cost than expected. -
There are ways you can get the money back, but to do so the deposits would have had to be made to an employee who was never in an HSA or if the funds exceeded the statutory maximum amounts. It appears from your post that you may have deposited too much on a per pay period, meaning the employee gets $1,200 per year, and you deposit $100 per month, but this past pay period you deposited $150. If this is the case, there is no need to recoup, just adjust your next deposit. Did this answer your question?
