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National Retirement Services, Inc.
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National Retirement Services, Inc.
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Blue Ridge ESOP Associates
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Retirement Plan Administration, Consulting and Design Firm
in CT, NJ, NY

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Sheet Metal Benefit Plans Administrative Corporation
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Ascensus
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Hooker & Holcombe, Inc.
in CT

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Insurance Brokerage - Westchester Area
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Hooker & Holcombe, Inc.
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Executive Compensation: Strategy, Design, and Implementation
June 18, 2015 in NY
(American Law Institute Continuing Legal Education Group [ALI CLE])

Certificate Series
June 20, 2015 in IL
(International Foundation of Employee Benefit Plans [IFEBP])

IRA Required Minimum Distributions
June 23, 2015 WEBCAST
(Ascensus)

IRA Distributions
September 3, 2015 WEBCAST
(Ascensus)

Employee Benefit Plans of Tax-Exempt and Governmental Employers: Featuring Practical Solutions
September 10, 2015 in DC
(American Law Institute Continuing Legal Education Group [ALI CLE])

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[Official Guidance]

Text of CMS Bulletin on Proposed Out-of-Pocket Cost Comparison Tool for the Federally-Facilitated Marketplaces (PDF)
"[CMS] is developing an Out-of-Pocket (OOP) Cost Comparison Tool ... [which] will allow shoppers in the Federally-facilitated Marketplaces (FFMs) to see estimates of total spending (to include premiums and cost-sharing) across various health insurance plans.... [CMS anticipates] this comparison tool would be available to consumers for the 2016 annual open enrollment period ... [CMS requests] public input on ... [1] the utilization and cost data; [2] use of health plans' cost sharing data; and [3] user input regarding consumer demographics ... [and] whether it would be helpful to make the source code of an OOP Cost Comparison Tool available for use by State-based Marketplaces (SBMs) including the timing and preferred format for providing this information." (Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS])  

[Advert.]

Private & Public Exchange Summit, July 15-16

Join Payer and Exchange executives in July for the 6th Annual Private and Public Exchange Summit. The Summit will explore approaches for health plans and exchanges to improve market share, encourage engagement, and reduce the cost trend.

[Official Guidance]

Text of HHS Request for Comments on the Requirements for the Health Plan Identifier
"[S]ince the publication of the HPID final rule, the nation's health care system has experienced sweeping changes, including implementation of the [ACA's] marketplaces.... [HHS is] requesting information regarding ... [1] The HPID enumeration structure outlined in the HPID final rule, including the use of the CHP/SHP and OEID concepts. [2] The use of the HPID in HIPAA transactions in conjunction with the Payer ID. [3] Whether changes to the nation's health care system, since the issuance of the HPID final rule published September 5, 2012, have altered your perspectives about the function of the HPID." (U.S. Department of Health and Human Services [HHS])  

[Guidance Overview]

Tacoma Is Third City in Washington State to Mandate Paid Leave
"Starting February 1, 2016, nearly all private sector employers must provide employees who work in Tacoma specified amounts of accrued, job-protected paid leave for personal illness, family care, domestic violence, and bereavement.... Every private sector employer that employs at least one employee is covered by the law.... [A]ll employees, including full-time, part-time and temporary employees, accrue one hour of paid leave for every 40 hours worked within Tacoma (up to 24 hours within a calendar year) and may use up to 40 hours of paid leave in any calendar year." (Littler)  

GAO Report: Despite Some Delays, CMS Has Made Progress Implementing Programs to Limit Health Insurer Risk
"[CMS] considered market characteristics and program duration in designing the three programs mandated by the [ACA] to mitigate the risks issuers of health insurance faced starting in 2014. Each of the three programs -- risk adjustment, reinsurance, and risk corridors -- was intended to account for a different source of issuer risk, such as enrollee health status or high-cost medical claims.... GAO describes: [1] the factors that guided CMS's design of these programs, [2] the data collection systems CMS developed for these programs, [3] CMS's plans to monitor and evaluate the programs, and [4] issuer experiences with the programs." [Published: Apr 30, 2015. Publicly Released: Jun 1, 2015.] (U.S. Government Accountability Office [GAO])  

GAO Report: Premiums and Enrollment for New Nonprofit Health Insurance Issuers Varied Significantly in 2014
"This report examines [1] the status of the CO-OP program loans, [2] how CO-OP health plan premiums compare to the premiums of other health plans, and [3] enrollment in CO-OP health plans. GAO analyzed data from CMS and states; reviewed applicable statutes, regulations, guidance, and other documentation; and interviewed officials from CMS and seven CO-OPs that were selected based on the total amount of loans awarded, geographic region, and the type of health insurance exchange (i.e., federally facilitated or state-based exchange) operated in the state where the CO-OP offered health plans." [Published: Apr 30, 2015. Publicly Released: Jun 1, 2015.] (U.S. Government Accountability Office [GAO])  

Payroll HSA Contributions Face Risk of Early Elimination by Employers If Not Exempted from 'Cadillac Tax' (PDF)
"If your current HSA-qualified family health plan costs more than $17,000, including wellness programs, your firm is likely to incur excise tax liability in 2018 if anyone makes a maximum contribution.... Employer uncertainty may cause over-reaction and harm to HSAs, especially in high cost states.... Employers are likely to eliminate contributions through payroll in order to avoid paying the excise tax....Many HSA-qualified plans will likely serve as a 'safe haven' from the Cadillac tax for many years.... Like the Alternative Minimum Tax, over time, the Cadillac Tax will apply to all plans, including HSA plans." (American Bankers Association Health Savings Account Council)  

Federal District Court: Retiree-Only Health Plan Is Exempt from Lifetime Dollar Limit
"According to the participant, the prohibition on lifetime dollar limits should apply to retiree-only plans as a result of ERISA Section 715(a)(2), which generally provides that the health care reform rules take precedence over conflicting ERISA provisions. But the court disagreed, concluding that even though the PHSA no longer contains an explicit retiree-only exemption, this did not reveal a conflict between the provisions or indicate that Congress, in enacting health care reform, intended to eliminate the retiree-only exemption." [King v. Blue Cross and Blue Shield of Illinois, No. 3:13-CV-1254-CAB-JMA (S.D. Cal. May 13, 2015)] (Thomson Reuters / EBIA)  

Jury Still Out on Consumer-Driven Health Plans
"[C]onsumers tend to reduce their utilization of healthcare during their first one or two years in a CDHP, particularly through reductions in prescription drug spending.... [It] isn't clear whether the reductions in services tend to be necessary or unnecessary, and long-term utilization trends are not observable in most studies due to short study periods of only one or two years." (HealthLeaders InterStudy)  

How Do People Decide on Life Insurance and Long-Term Disability Insurance Coverage?
"[U]nlike in the pension world, very little is known about how individuals select their benefits packages, if their selections are optimal for their situations, or what employers can do to encourage the optimal benefit package selection. In this changing benefit landscape, it is important to determine three things: [1] What are current employer practices and their resulting take-up and coverage patterns? [2] Which practices influence employees' selections? and [3] What can employers do to make the employees' selections closer to the employees' optimal choices?" (Center for Retirement Research at Boston College)  

New Medicare Data Available to Increase Transparency on Hospital and Physician Utilization
"CMS is posting the third annual release of the Medicare hospital utilization and payment data (both inpatient and outpatient) and the second annual release of the physician and other supplier utilization and payment data.... The hospital data includes payment and utilization information for services that may be provided in connection with the 100 most common Medicare inpatient stays and 30 selected outpatient procedures at over 3,000 hospitals in all 50 states and the District of Columbia. The top 100 inpatient stays represented in the hospital inpatient data are associated with approximately $62 billion in Medicare payments and over 7 million hospital discharges." (Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS])  

Federal Investigators Fault Medicare's Reliance on Doctors for Pay Standards
"The [GAO] said Medicare officials usually accepted the recommendations they received from a committee of 31 doctors formed by the [American Medical Association] and medical specialty societies. Meetings of the panel, known as the Relative Value Scale Update Committee, are open to the public. But people who attend must sign a confidentiality agreement promising not to disclose information about the discussions." (The New York Times; subscription may be required)  

Humana Receives Interest from Potential Buyers, May Sell
"Humana received acquisition interest Friday -- a move that, if finalized, would create a potential domino effect of consolidation throughout a health insurance industry that faces increasing pressure to rein in costs.... Humana posted $1.1 billion of pretax income on its $48.5 billion in revenue last year, while its 2015 first quarter membership rose to 14.2 million and revenue increased 18 percent -- this despite falling short of Wall Street's expectations." (FierceHealthPayer)  

[Opinion]

Nudging Our Way Past Inertia in the Health Insurance Exchanges
"Most exchanges automatically reenroll participants in the same plan they had in the previous year.... [T]he first time that many enrollees will find out about their premium spikes will be when they get their first bill.... [The authors suggest] that at renewal time, all individuals are asked to affirm whether they want to keep their plan, switch plans, or drop coverage. Those who do not respond are automatically reenrolled, but are not necessarily assigned to their own plan. There are a number of options for reassignment that would avoid financial surprises -- for example enrollees could be reassigned to any plan that cost no more than the second cheapest silver plan." (David Dranove and Craig Garthwaite, Kellogg School of Management)  

[Opinion]

The Flip Side of Halbig
"[If] getting rid of the subsidies renders coverage 'unaffordable' (an ACA 'term of art), then the penalty no longer applies, thus saving consumers even more money. In fact, the 'study finds that 11.1 million people will be free of the individual mandate, and more than a quarter million businesses will be liberated from the employer mandate' if the plaintiff prevails[.]" (InsureBlog)  

American Pension Services, LLC Celebrates 15 Year Anniversary This Month
American Pension Services, LLC

Robert E. Rice, Former Chief Counsel to SEC Chair, Joins Ropes & Gray in New York
Ropes & Gray

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