GBurns

WDWC ?

Rev Ruling 61-146 had no employee pre-taxing. The employer used employer finds to reimburse the employee. In this OP it is the employee pre-taxing employee money, then having that money sent to the insurance company, just like in a POP 125 plan. I am still not sure what the OP is describing and prefer not to speculate in the hope that it will be clarified.

You forgot about the habit of some to add an "h" to words which begin with a vowel. HAppleby, for example. Hemphasize your haiches you hignorant hass. (Part of an old Jamaican joke).

Note the wording used in paragraph 2 of page 1, "The effective date of the new regulations is generally plan years beginning 1/1/2009 or later. Although it also does state that employers have the option to rely on them prior to the effective date. That being said, I still wonder about such early adoption and think that there is some question about what is being said in the OP.

If the employer is reimbursing the employee for premiums that the employee paid for privately purchased health insurance, Why is there any election and premium deduction ?

Now I am curious as to how you treat "h".

As you said, the new Prop. Regs came out in August 2007 and I recall that it was to take effect January 2009. I could not imagine that someone made a decision to implement this change in time for plan year 2008. If a calendar year plan with enrollment in November, they would have had to make the decision almost immediatley so as to have the PD amended and SPD etc produced in time. It just did not seem plausible that they could have been relying on the new Prop. Regs. The scenario in your last paragraph raises questions. Under that scenario there is and would be no substantiation or verifcation of premium payment. If there were then the excess deduction would have been reported after the very first month so there would be no accumulation. It also raises questions regarding the company's Accounts Payable procedures. What invoice was the premium remitted against? And why was an amount in excess of the invoice amount paid ? To many things raise questioons, so I think that there is something that I am not understanding, probably in the terminology. Then again it could just be my medication.

I have always heard Qua (as in Qua-lified) - dro (as in dro-ne).

There are inherent problems with such tools. 1. The tools are usually provided by pro-HSA entities and biased. The bias is not deliberate but is caused by the lack of info and comparative data, so it is a guessing game. 2. The consumer is asked to anticpate medical expenditures. The reality is that very few know and can even find out what the costs of any medical procedure will be. Just pick any procedure for any ailment or disease then call the Dr's office and ask. Don't forget, the hospital charges, the Operating Room charges, the anethesiologist, the pathologist etc etc. 3. The consumer has no way of knowing, at time of enrollment, the schedule of payments agreed to between the HDHP and the service providers, so there is no way to compare co-pays and out of pocket expenses between the existing health insurance and the new HDHP, in fact they do not even know what the current insurance pays.

I do not understand. A "Premium Reimbursement Account" within a Cafeteria Plan ? Who gets reimbursed and for why ? What do you mean by "premium reimbursement election" ? If this is salary reduction for the employee share of the health insurance premium, then why "reimbursement" ? I also have a problem with "we still cannot account for all the extra funds paid out by the end of the year." Paid out to Whom ? Insurance premiums are usually forwarded to the insurance coomppany each month. If excess premium is paid it should show up immediately, so I do not understand why you would be doing anything at the end of the year rather than the very next month after the first excess payment.

I find that the main reason plan participants have problems is because they relied on what someone is HR or Benefits said. Why not just call a pharmacy or Dr and ask about the pricing ? It seems much better to hear it in advance from the person who is going to do it.

Personally, I would take some of the MHM suggestions with a few grains of salt. Some I find questionable or in need of much more explanation.

MaryMM I don't think that I misread the OP, so I have to wonder why you concluded that "You're already making an employer contribution to the HSA " ? Also " net cost was the same or lower" but for whom ? Employer or employee ? Over how long ? Actual or projected ?

SPD = Summary Plan Description. Sort of like a super Outline of Coverage. You should have received something similar for your other benefits especially the cafeteria plan and health insurance. Have you looked to see the list of available Drs etc that you will have under the HDHP ? The High Deductible etc is not what seems to concern most people as much as the paying full price plus the restrictions on Drs and hospitals. BTW the paying full price up front can also be an issue with Drs and Hospitals. The calculation of your share is often done using full price. Make sure that you research and understand what you are getting into. Pen and paper using scenarios could be helpful.

The employee acting as a conduit does not seem on point with the OP. In the OP, the taxpayer is personally going to "remove" and "substitute" the asset. There is no mention or suggestion of acting as a conduit or subrogating rights or anything else. Then whether acting directly or as a conduit, I think the issue of constructive receipt presents problems.

It seems to depend on the services offered by your HSA administratoor. Most plans seem to have you pay full price up front then get reimbursed later. However, I have heard of HSA plans that have provider claims submission (which would get a discount) or a Debit card (usually full price). You have to get more details from HR. The are required to give you an SPD which is supposed to give adequate info, and they are also supposed to have other documents which you are allowed to see upon request. I am not sure that the HSA must have a Plan Document but it must have an SPD. I trust that you do realize that in order to have the HSA you must also change you health insurance to a high deductible plan. An HSA/HDHP is not something that is tried, it is something that you fully consider and calculate before making the choice.

I do not recall ever seeing a VEBA that performs TPA services. I am assuming that you mean claims administration etc. I thought that it was usuallly outsourced.

Have you considered the possibility that the reason for low particpation might be simply because the plan participants have considered the facts and have decided that the HSA is not a good option for them ? If this is so, Why would you want to try and persuaude them otherwise? A comparison of options might be better.

So what do you use for the employee share of the health and dental etc ?

Wouldn't the use of a SRA specifically for the HSA conflict with the cafeteria plan SRA ? In other words shouldn't it be a additional line item on the existing SRA ? Have you amended your PD to include an HSA and HDHP ?

1. Except for Participants, any and all of the others could and might be fiduciaries. It depends on their duties, responsibilities, control, authority and actions. 2. Not knowing both sides of the story, I can only suggest that the Participant verify the address used by the TPA and then request that the EOB be sent by Certified mail or with other proof of delivery.

Thanks for the plug. The website has been "under construction" for over 2 years and will probably never be up. It turned out that two "test" websites only got people who were not in a position to make decisions and who, although they were senior executives could not and/or would not make a recommendation to their CEO. So we market by making direct contact with the target CEOs. Time consuming and difficult, yes, but definitely more produuctive. Most of the strategies that I employ or know of work with larger groups. This is mainly caused by the availability of better claims experience information and economy of scale. The claims information in many areas is sometimes only available for groups larger than 200 but it depends on the area. Also even with savings of around 40% the $ amount is sometimes not attractive enough to interest the company if it is a small employer, although to Exxon over $2,500 per employee per year was not attractive because it paled in comparison to overall profit. After all it was only $200,000,000. We do not sell or promote MERPs, HRAs, HSAs etc and we try not to sell any health insurance intially, although we eventually end up taking over (or intend to) as agent of record especially in larger cases. We instead first restructure the tax deductions by an accounting change etc., then we reduce the premiums on the current insurance policies by various techniques using predictive modeling, lasering, centers of excellence and disease management, dependent etc verification and claims auditing etc. We do not do all of these for everyone initially but progress in stages as the client is able to digest the shock of realizing that these things are readily available, they just did not see the forest because of all the trees. Much of what we do is outsourced to much larger well established companies who have long had these thing available. The main thing we do inhouse is the tax strategy. Much is done by the client's existing insurance carrier, under our direction. The client could have had it done before and the insurance company could have offered it, but they just never understood what their computers could do. That itself presents the biggest hurdle. The client's Benefits and HR are afraid that the CEO might realize and ask How come the staff did not know about these things? That is why we have to circumvent HR/Benefits and make direct contact with the CEO. If you have personal contact with the CEOs of large companies, send me an email and we can see if anything is available for you or at the least give you some pointers if you have a warm market.

marie Three things are quite possible: 1. You did not hear her correctly. 2. You did not understand what she said. And most likely, 3. She does not understand what she is doing but thinks that she has found a "secret". Possibly why it seems to be a "secret" that no one else knows, is that no one else seems to be doing it. Maybe they are not doing it because it simply does not work. That does not mean that there are not many little known or little used ways of reducing healthcare costs. There are ways and they are little known and little used. I can recall a person who sold HRAs in the 1980's. He could not get much credibilty for almost 20 years. He developed many many excellent presentations and made good money but nothing near what he should have made. There are many excellent ideas that have gained no traction mainly because they did not come from one of the major consulting firms etc. To expand on the advice given by J Simmons, get a thorough explanation then get an opinion. At this point you probably do not know enough to be able to ask proper questions. Also read up on the subject first. Much good info is available on the Internet and much has been written by many law firms etc.

The OP said "before service is credited", the restatement to "prior to the performance of services" might be incorrect. Personally, I have no idea what the posted means by "credited" in this context.

Why "quote the same COBRA rate billed to a divorced spouse mandatorily or a domestic partner permissively" ? I also am not sure that I have seen (not that I have really looked) the sinlge rate being used for non-spouse dependents "historically". I do not know why you think that actuarial logic is any more relevant than any other logic, but: What happens if the premium tiers are Employee Only; Employee & Spouse; Family or something similar such as Employee & 1 Dependent; Employee and 2 Dependents etc ? Such tiering implies that there is a calculated amount for non-spouse dependents. So charging the Employee Only (Single) rate should be improper and actuarially questionable.