Conversion Specialist
American National Insurance Company
in TX

Customer Service Representative
YMCA Retirement Fund
in NY

Senior Implementation Specialist
MetLife
in NC

Senior Plan Document Specialist
MetLife
in NC

Manager - Plan Documentation
MetLife
in NC

Qualified Plan Design Analyst
MetLife
in NC

Relationship Manager - Team Lead (Institutional Trust & Custody)
U.S. Bank
in FL

Senior Plan Document Specialist
MetLife
in NC

401k Client Service Associate
The Noble Group
in TX

Data Conversion Specialist
Transamerica Retirement Solutions
in NY

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Employer Mandate Delay: Overview of New Final Regulations
February 19, 2014 WEBCAST
(Hill, Chesson & Woody)

ACA Employer Mandate Delay Provides Some Relief, but Challenges Remain
February 21, 2014 WEBCAST
(Mercer)

The Final 4980H Regulations: Complying with the ACA’s Employer Shared Responsibility Rules
February 27, 2014 WEBCAST
(Bloomberg BNA)

Take Charge of Your Financial Future
February 28, 2014 WEBCAST
(Employee Benefits Security Administration (EBSA), U.S. Department of Labor)

Tracking Full-Time Employees for Employer Play or Pay: Look-Back Measurement Under Final IRS Regulations
March 6, 2014 WEBCAST
(Thomson Reuters / EBIA)

Retirement Plan Insights Seminar
May 6, 2014 in PA
(McKay Hochman Co., Inc.)

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[Guidance Overview]

The Forgotten Penalty: ACA's $100/Day Excise Taxes Could Devastate Employers, Starting Now
"[A] potentially much more significant penalty has gone virtually unnoticed: an excise tax of $100 per affected individual, per day that will be imposed on any employer -- regardless of the size of its workforce -- that offers a group health plan that fails to comply with a laundry list of coverage requirements and restrictions ... set forth in [an] accompanying chart.... The excise tax is triggered if a plan fails to satisfy any one mandate, even partially. So be very, very careful in establishing and administering your health care plan." (Hinkle Law Firm LLC)  

[Advert.]

Plan Now To Attend the Health Care Management Conference

The International Foundation's Health Care Management Conference, help April 7-9 in Orlando, will provide full health care reform analysis along with the most up-to-date legal requirements and practical issues to address in 2014. Register Now!

[Guidance Overview]

Regs on Employer 'Pay or Play' Mandate Affect Educational Institutions in Major Way
"The final regulations clarify that hours worked by students in a federal work-study program or other similar program subsidized by the government, are not included in determining whether the student is a full-time employee.... Under the safe harbor method, adjuncts are credited with 2.25 hours of service for every hour of teaching and one hour of service for each non-teaching hour worked.... This safe harbor is available until the end of 2015.... For all employers other than educational institutions a returning employee may be treated as a new hire as long as there is a break in service of at least 13 weeks. For educational institutions ... the break in his or her service must be at least 26 weeks." (Ogletree Deakins)  

[Guidance Overview]

Employer Mandate Delay Provides Some Relief, But Challenges Remain (PDF)
"The relaxation of the definition of 'substantially all' employees will provide transitional relief for some employers.... The employer could still be subject to the $3,000 ... payment for each full-time employee who receives a premium tax credit for subsidized coverage in the public marketplace. This could occur if the employer plan does not have affordable contributions or does not meet the minimum plan value requirement -- or is not offered to 100% of full-time employees." (Mercer)  

Text of 6th Circuit Ruling: Employer Cannot Rely on 'Theoretical' Job to Deny Disability Benefits (PDF)
"[T]o the extent that the administrator interpreted the Plan language -- requiring that the claimant's disability prevents him 'from engaging in any occupation or employment for remuneration or profit' -- to include a job that exists only in theory, that interpretation is in error.... Just as 'every business or occupation' does not include literally every form of earning money, 'any occupation or employment' also does not include jobs that exist only hypothetically." [Kyle Kennard v. Means Indus., Inc., No. 13-1911 (6th Cir. Feb. 13, 2014)] (U.S. Court of Appeals for the Sixth Circuit)  

Text of 11th Circuit Ruling: Georgia Prompt Pay Laws Are Preempted by ERISA and Not Applicable to Self-Funded Plans (PDF)
"The [Georgia Insurance and Safety Fire Commissioner] argues that only those state statutes that regulate or conflict with substantive aspects or coverage determinations of ERISA plans have been found to 'relate to' such plans. According to the Commissioner, IDEA's prompt-pay or notice requirements are procedural, and therefore cannot 'relate to' ERISA plans. We are not persuaded by this argument." [America's Health Insurance Plans v. Ralph Hudgens, No. 13-10349 (11th Cir. Feb. 14, 2014)] (U.S. Court of Appeals for the 11th Circuit)  

7th Circuit Denies Recovery by Self-Insured Health Plan of Amounts Paid to Hospital for Ineligible Dependent
"With respect to child coverage, some plans simply require the employee to acknowledge the child's status at enrollment, while other plans may require further documentation of the child's status (e.g., copies of birth or adoption records). Plans requiring documentation should describe the documentation requirements in plan documents and SPDs and should timely review and act on documentation received in order to avoid or reduce claims paid for ineligible dependents." [Kolbe & Kolbe Health and Welfare Ben. Plan v. Medical College of Wisconsin, Inc., Nos. 12-3837 & 12-3929 (7th Cir. 2014)] (Thomson Reuters / EBIA)  

Incentives to Shape Health Behaviors
"Person-centered, as opposed to patient-centered, incentives allow individuals to self-match to incentives and engage them in the decision-making process. This could lead to better participation and more successful goal achievement. Dimensions to be considered when designing person-centered incentives include: risk preferences, personal tastes, competitiveness, altruism, timing preference, and others." (Robert Wood Johnson Foundation)  

Beyond Obamacare: Put the Focus on Cures, Not Costs (Part 1)
"[A]ccording to CMS, Obamacare adds roughly $621 billion over 11 years to national health spending. And while this may be a lot of money ... it amounts to 1.5 percent of the $40.7 trillion what we would have spent without Obamacare. The biggest effect of Obamacare, then, is to shift spending ... On the one hand, high costs may be a function of high volume. On the other hand, high costs may come from high prices. The verdict on U.S. spending is that it's generally driven by price increases rather than volume." (Forbes)  

Think Under 50 Employees Definitely Means No Obamacare? Think Again
"[E]very business should be asking: are our independent contractors really independent? The risk of having them ruled to be employees isn't theoretical. The IRS is active in independent contractor reclassification efforts, and more scrutiny is coming. No matter how you label someone, the substance of the work relationship will control. The IRS says you must evaluate 20 factors and assess whether you are controlling the method, manner and means of the work. No one factor is controlling." (Forbes)  

2nd Circuit Says Self-Insured Plan and TPA Were Not Subject to Vermont's Health Plan Data Reporting Requirement
"Although the Second Circuit's broad reading of Travelers is good news for self-insured plans in that jurisdiction, it remains to be seen whether the decision will be reviewed by the U.S. Supreme Court and how it may fare there. The court noted that 16 other states collect health claims data (although some do so voluntarily or exclude self-insured plans)." [Liberty Mut. Ins. Co. v. Donegan, No.12-4881-cv (2nd Cir. Feb. 4, 2014)] (Thomson Reuters / EBIA)  

Five Pitfalls of Defined Contribution Health Plan Strategies
"There's no crystal ball to tell us if the contribution strategy can solve the critical issues of high health care costs, but a good prediction may be based on an understanding of proven failures in health care planning. [1] Ignoring chronic disease.... [2] Confusing high-cost with high-quality.... [3] Being lured by defined-contribution plans.... [4] Abandoning team-wellness strategies.... [5] Failing to evaluate and align vendor-partner goals." (Employee Benefit News)  

2013 Form M-1 Now Available on EBSA Website
"The Form M-1 is an annual report that must be filed by Multiple Employer Welfare Arrangements (MEWAs). In general, MEWAs are arrangements that offer health and other benefits to the employees of two or more different employers.... The Form M-1 must be filed no later than March 1 following any calendar year for which a filing is required. Since March 1, 2014 is a Saturday, the 2013 Form M-1 must be filed no later than the next business day, March 3, 2014. A one-time extension of time to file will automatically be granted if the administrator of the MEWA or ECE requests an extension." (Employee Benefits Security Administration, U.S. Department of Labor)  

[Opinion]

A Response to Uwe Reinhardt on ACA Premium Subsidies
"[I]f we take all of the tax subsidies for employer-provided health insurance and add to it all of the revenue used to pay for the (ObamaCare) subsidies in the exchanges, there is more than enough there to give a tax credit of $2,500 to every adult and $8,000 to every family of four. As it turns out, this is what the CBO estimates is needed for new enrollees in Medicaid. So we could not only give everyone the same tax credit, we could also give everyone the option to use his credit and buy into Medicaid." (John Goodman's Health Policy Blog)  

[Opinion]

Why the White House Is Panicking About the ACA
"Health insurance is a way of protecting one's financial resources against the expense of a catastrophic illness.... People living paycheck to paycheck have trouble maintaining a reserve for unexpected medical expenses. So as an alternative to personal savings and higher wages, they appear to be willing to take less in take home pay in return for a modest amount of health insurance.... What is irrational is to use almost all of your paycheck to buy a health insurance plan with an unlimited benefit -- one that, say, is able to pay a $1 million medical bill. Why would you buy a million dollars' worth of coverage if you don't have a million dollars of assets to protect?" (John Goodman's Health Policy Blog)  

[Opinion]

Hobby Lobby: The Parties' Common Ground ... and a Fundamental Divide About Religious Exemptions for For-Profit Employers
"The common ground is the parties' agreement that individuals can and do exercise religion in all aspects of their lives, including when they are engaged in commercial activities.... [T]he implicit theme of the government's threshold argument is that Congress could not have intended to require religious exemptions for for-profit employers generally. This argument is grounded in history, and in a pronouncement of the Supreme Court in a 1982 free exercise case." (Balkinization)  

[Opinion]

A Physician's Perspective on EBRI's Report on HSAs
"[O]nly a small fraction of one percent of our national health expenditures comes from health savings accounts. Since most people with HSAs will go ahead and get the care that they need, their diligent shopping can only have had an impact on maybe ten percent of the HSA spending, meaning that HSAs may have reduced spending by only about one one-hundredth of one percent of our NHE.... What really is important is the high-deductible insurance plan that is coupled with the HSA. That is what makes the patient a 'diligent' shopper, except that it really doesn't since most of our health expenditures are not amenable to shopping." (Physicians for a National Health Program [PNHP])  

More Organizations Speak Out Against New Medicare Advantage Rate Cuts
America’s Health Insurance Plans (AHIP)

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