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All News > Health Plan Administration

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Text of 2022 IRS Form 1095-A: Health Insurance Marketplace Statement (PDF)
Internal Revenue Service [IRS] Link to more items from this source
[Official Guidance]
Sept. 30, 2022

"This Form 1095-A provides information you need to complete Form 8962, Premium Tax Credit (PTC)."

Tags: Health Plan Administration

Text of IRS Publication 5164: Test Package for Electronic Filers of ACA Information Returns (AIR), Processing Year 2023 (PDF)
Internal Revenue Service [IRS] Link to more items from this source
[Official Guidance]
Sept. 30, 2022

18 pages, rev. Sep. 2022. "[This document] contains general and program specific testing information for use with ACA Assurance Testing System (AATS).... Software Developers must pass IRS AATS scenarios for the forms and tax year that the software package will support.... Transmitters and Issuers must pass a one-time communication test for the forms they will file."

Tags: Health Plan Administration

Inflation's Impact on 2023 Open Enrollment
Bolton Link to more items from this source
Sept. 30, 2022

"Employers can take steps now to help their employees better understand their benefits options and make more informed decisions.... [1] Communicate with employees about benefits early.... [2] Use multiple communication channels.... [3] Employ clear language and personalized messaging.... [4] Highlight the services that come with coverage."

Tags: Health Plan Administration

IRS Disaster Relief Announcement FL-2022-19, for Victims of Hurricane Ian in Florida
Internal Revenue Service [IRS] Link to more items from this source
[Official Guidance]
Sept. 30, 2022

"Victims of Hurricane Ian that began September 23 in Florida now have until February 15, 2023, to file various individual and business tax returns and make tax payments.... Individuals and households affected by Hurricane Ian that reside or have a business anywhere in the state of Florida qualify for tax relief."

Tags: Health Plan Administration  •  Retirement Plan Administration

AHA, AMA Dismiss Surprise Billing Rule Lawsuit, Plan Further Legal Action
aequum Link to more items from this source
Sept. 30, 2022

"The American Hospital Association (AHA) and American Medical Association (AMA) filed a motion to dismiss their lawsuit challenging the federal government's final rule on surprise billing released last year, but cautioned more litigation is pending. The health care lobbying groups say the August 2022 final rule on arbitration still poses concerns for providers."

Tags: Health Plan Administration  •  Health Plan Costs

Editor's Pick Fourth Quarter 2022 Quick Hits for Plan Sponsors and Administrators
Jackson Lewis P.C. Link to more items from this source
[Guidance Overview]
Sept. 28, 2022

"With the first RxDC reporting deadline of December 27, 2022, fast approaching, plan administrators should discuss RxDC reporting with their providers now to develop a compliance plan. As the CMS warns, HIOS accounts can take up to two weeks to create.... [F]irst dollar coverage for insulin will protect Health Savings Account (HSA) eligibility for those who require an insulin regimen. Employers should determine if their plan requires an amendment to implement this change.  ... [FAQs Part 54] confirm that health reimbursement arrangements, health savings accounts, and health flexible spending accounts can reimburse the costs of over-the-counter contraception that is not otherwise paid or reimbursed by a health plan or issuer. Employers should review their plans to determine if any amendments are needed to conform to the FAQs."

Tags: Health Plan Administration  •  Health Plan Design

Cyber Criminals Targeting Healthcare Payments
Withum Smith+Brown, PC Link to more items from this source
Sept. 28, 2022

"The FBI noted that thus far in 2022, hackers have already stolen more than $4.6 million USD from healthcare organizations by accessing customer accounts and altering payment details causing critical operational, reputational, regulatory, and legal impacts.... Within the FBI Notification are practical steps for your organization to protect against criminals targeting your organization."

Tags: Cybersecurity  •  Health Plan Administration

IRS Disaster Relief Notice AK-2022-04, for Alaska Victims of Severe Storm, Flooding, and Landslides
Internal Revenue Service [IRS] Link to more items from this source
[Official Guidance]
Sept. 28, 2022

"Victims of Alaska severe storm, flooding and landslides occurring between September 15 and September 20, 2022, now have until February 15, 2023, to file various individual and business tax returns and make tax payments ... Individuals and households affected by severe storm, flooding and landslides that reside or have a business in the Regional Education Attendance Areas of Bering Strait, Kashunamiut, Lower Kuskokwim and Lower Yukon qualify for tax relief."

Tags: Health Plan Administration  •  Reporting to Government Agencies  •  Retirement Plan Administration

October 14 Deadline: Medicare Part D Notice of Creditable (or Non-Creditable) Coverage
Fraser Trebilcock Link to more items from this source
[Guidance Overview]
Sept. 27, 2022

"With respect to group health plans including prescription coverage offered by an employer to any Medicare Part D eligible employees (whether or not retired) or to Medicare Part D Medicare-eligible spouses or dependents, the employer must provide those individuals with a Notice of Creditable or Non-Creditable Coverage to advise them whether the drug plan's total gross value is at least as valuable as the standard Part D coverage (i.e., creditable). Medicare Part D notices must be provided to Medicare-eligible individuals prior to October 15th of each year (i.e., by October 14th)."

Tags: Health Plan Administration  •  Medicare

Surprise Billing Arbitration Updates: New Lawsuit and New Context on Rate-Setting Approaches
Healthcare Financial Management Association [HFMA]; free registration required Link to more items from this source
Sept. 26, 2022

"[1] A provider association that earlier won a lawsuit over the No Surprises Act arbitration process is going to court again over the same issue. [2] Delays in resolving arbitration cases can be expected to continue. [3] Findings of a new study indicate the diverging impact of using a rate-setting approach as opposed to a percent-of-charges benchmark to resolve out-of-network payments." [Texas Medical Association v. HHS, DOL and Treasury, No. 22-0372 (E.D. Tex. complaint filed Sep. 22, 2022)]

Tags: Health Plan Administration  •  Health Plan Costs

Final Rule Changes No Surprises Act Requirements
Sheppard Mullin Link to more items from this source
[Guidance Overview]
Sept. 23, 2022

"The Final Rule addresses specific disclosure requirements for group health plans and health insurance issuers related to the Qualified Payment Amount (QPA) for out-of-network (OON) services and sets forth the factors and information which certified Federal Independent Dispute Resolution (IDR) entities must consider in arbitrating disputes for OON services or items. The Final Rule is effective October 25, 2022, for services/items rendered during plan years beginning or after January, 1, 2022."

Tags: Health Plan Administration  •  Health Plan Design

Agencies Release Additional Surprise Billing and Transparency Guidance
HUB International Link to more items from this source
[Guidance Overview]
Sept. 22, 2022

"While much of the mechanics of the surprise billing protections will be handled by carriers and TPAs, employers should be familiar with the relevant parts of these FAQs. They may also want to consider moving any links to their machine readable files back onto the TPA's website, if possible."

Tags: Health Plan Administration

Total Rewards Communication for Your Employees
Willis Towers Watson Link to more items from this source
Sept. 22, 2022

"[R]eplacing the total rewards statement with a digital, highly-personalized total rewards experience [provides] a tool that accurately reflects the multiple components of the total rewards employers deliver to employees.... The ideal personalized total rewards view encompasses pay, stock, health and wellbeing, retirement, and work/life benefits.... Embedding personalized messages that drive employee behaviors is the real value behind the communication."

Tags: Health Plan Administration  •  Retirement Plan Administration

Prescription Drug Reporting Due This Year: Employer Action Required
HUB International Link to more items from this source
[Guidance Overview]
Sept. 21, 2022

"Given the short timeframe between now and the looming reporting due date, employers should work with their insurance carriers, TPAs, PBMs, and other service providers to ensure prescription drug reporting is accurately handled and timely submitted. If local circumstances require that the employer directly report certain information on its own plan's behalf, the employer should familiarize itself with the reporting instructions released by CMS[.]"

Tags: Health Plan Administration  •  Prescription Drug Costs

DOL Eases Independence Rules for Employee Benefit Plan Accountants
Mercer Link to more items from this source
[Guidance Overview]
Sept. 21, 2022

"The updated interpretative bulletin [IB 2022-01] lets plan administrators hire a qualified public accountant who held the plan sponsor's publicly traded securities during the plan year covered by the audit if the accountant divests those securities before starting the engagement. The updated guidance ... takes effect immediately."

Tags: Health Plan Administration  •  Retirement Plan Administration

Deadline for Medicare Part D Creditable/Non-Creditable Coverage Notices Is October 14
Buck Link to more items from this source
[Guidance Overview]
Sept. 20, 2022

"Plan sponsors that offer prescription drug coverage must provide notices of creditable or non-creditable coverage to Medicare-enrolled individuals before each year’s Medicare Part D annual enrollment period -- this year, by October 14. The notice obligation is not limited to retirees and their dependents but also includes Medicare-enrolled active employees and their dependents and Medicare-enrolled COBRA participants and their dependents."

Tags: Health Plan Administration  •  Medicare

Text of IRS Disaster Relief Notice PR-2022-10, for Puerto Rico Victims of Hurricane Fiona
Internal Revenue Service [IRS] Link to more items from this source
[Official Guidance]
Sept. 20, 2022

"Victims of Hurricane Fiona beginning September 17, 2022, now have until February 15, 2023, to file various individual and business tax returns and make tax payments ... Individuals and households affected by Hurricane Fiona that reside or have a business in all 78 municipalities in Puerto Rico qualify for tax relief."

Tags: Health Plan Administration  •  Reporting to Government Agencies  •  Retirement Plan Administration

Third 'No Surprises Act' Rule Issued; Claims Backlog Persists
ArentFox Schiff LLP Link to more items from this source
[Guidance Overview]
Sept. 16, 2022

"At bottom, the new rule appears to be more provider-friendly than the prior versions. However, more than 46,000 disputes have been filed since the Departments opened their online portal for submissions in April 2022, a figure far outpacing the Departments’ initial estimates for the entire first year."

Tags: Health Plan Administration  •  Health Plan Costs

Upcoming Rx Reporting: What About Third-Party Point Solutions?
Mercer Link to more items from this source
Sept. 16, 2022

"As Dec. 27, 2022 -- the deadline to report detailed data to [CMS] about prescription drug pricing and healthcare spending -- approaches, employers should consider whether they must report costs associated with third-party point solutions that provide medical care and are offered to employees. Given the wide range of point solutions available -- from technology to drive engagement, to disease management, fertility benefits, and behavioral health carve-outs -- there isn't a simple answer."

Tags: Health Plan Administration  •  Prescription Drug Costs

Court Allows GINA Claims to Proceed Against City of Chicago as Wellness Program Sponsor
Thomson Reuters / EBIA Link to more items from this source
Sept. 16, 2022

"The court noted that GINA allows an employer to obtain genetic information if the employee provides 'prior, knowing, voluntary, and written authorization.' Whether the wellness program is 'voluntary' in light of the financial penalty for nonparticipation is to be determined in further proceedings." [Williams v. City of Chicago, No. 20-0420 (N.D. Ill. Jul. 25, 2022)]

Tags: Health Plan Administration  •  Health Plan Design

Text of Agencies' Request for Information: Advanced Explanation of Benefits and Good Faith Estimate for Covered Individuals
U.S. Treasury Department; U.S. Department of Labor [DOL]; U.S. Department of Health and Human Services [HHS]; and Office of Personnel Management [OPM] Link to more items from this source
[Official Guidance]
Sept. 15, 2022

26 pages. "This document is a request for information (RFI) to inform DOL, HHS, and the Treasury and OPM's rulemaking for advanced explanation of benefits (AEOB) and good faith estimate (GFE) requirements of the No Surprises Act, which was enacted as part of the Consolidated Appropriations Act, 2021 (CAA). This RFI seeks information and recommendations on transferring data from providers and facilities to plans, issuers, and carriers; other policy approaches; and the economic impacts of implementing these requirements."

Tags: Health Plan Administration  •  Health Plan Costs

Affordability Percentage for Employer Health Coverage Will Shrink in 2023
Mercer Link to more items from this source
[Guidance Overview]
Sept. 15, 2022

"Employers should review the required employee contribution for 2023 coverage if they plan to meet the ACA's affordability limit under the applicable safe harbor. For the many plans using the FPL affordability safe harbor, the considerations differ for calendar- and noncalendar-year plans."

Tags: Health Plan Administration  •  Health Plan Costs

Upcoming Key Compliance Deadlines and Reminders for Fourth Quarter 2022
Lockton Link to more items from this source
Sept. 15, 2022

"Open enrollment season is here once again! The rush of meeting deadlines to offer benefits, educate employees on benefit changes, and make sure all required notices are provided and filings are timely made could cause some stress and anxiety.... Here are potential action items for the fourth calendar quarter (through Dec. 31, 2022)."

Tags: Health Plan Administration

Federal Authorities Clarify Independent Dispute Resolution Process Under No Surprises Act
Fisher Phillips Link to more items from this source
[Guidance Overview]
Sept. 14, 2022

"The interim final rules require plans and issuers to disclose the QPA for each item or service to providers and facilities with each initial claim payment or notice of denial of payment in any case where the QPA set the relevant cost-sharing amount. Additionally, when a plan or issuer changes a provider or facility's service code to one of lesser value, the plan or issuer must now provide additional information for this 'downcode' process."

Tags: Health Plan Administration  •  Health Plan Costs

2023 ACA Compliance Planning: Important Steps for Employers
Fisher Phillips Link to more items from this source
[Guidance Overview]
Sept. 14, 2022

"[1] Adjust to a lower affordability threshold ... [2] Be aware of the affordability safe harbors ... [3] Recognize that ESRP penalty amounts continue to rise ... [4] Calendar the Form 1094-C/1095-C deadlines ... [5] Use current draft ACA reporting forms."

Tags: Health Plan Administration  •  Health Plan Costs

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