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[Guidance Overview]
Plan Sponsors, Insurers and Administrators Should Check Out-of-Pocket Limits and Other ACA Requirements
"Special care and scrutiny should be applied if the group health plan uses multiple service providers to help administer benefits (such as one third-party administrator for major medical coverage, a separate pharmacy benefit manager, and a separate managed behavioral health organization). Separate plan service providers may impose different levels of out-of-pocket limitations and may utilize different methods for crediting participants' expenses against any out-of-pocket maximums."
(Solutions Law Press)
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[Guidance Overview]
IRS Issues Second Guidance on Cadillac Tax
"Because those who pay the tax cannot claim a deduction for the Cadillac tax and because they will be taxed on reimbursements that they receive [from employers and plan sponsors] for payment of the tax, they may also seek to be grossed-up for the taxes they pay on reimbursements. The calculation of the gross-up can be complex because reimbursements for the Cadillac tax paid are taxable, and reimbursements for tax paid on those reimbursements are taxable, etc. The IRS is considering how to address these situations and, in particular, the extent to which any gross-up can be excluded from the cost of coverage subject to the Cadillac tax."
(Ballard Spahr LLP)
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[Guidance Overview]
Cadillac Tax Guidance Addresses Health FSAs and More
"Among other issues,[Notice 2015-52] addresses: [1] Identification of which entities are liable for the excise tax. [2] Employer aggregation issues. [3] Allocating the tax among taxpayers. [4] How the tax is paid. [5] Other issues concerning the cost of applicable coverage that were not addressed in IRS Notice 2015-16.... [T]he IRS requested comments (due October 1, 2015) regarding the administrability of its proposals and issues involving Section 4980I in general."
(Practical Law Company)
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Current DOL Audit Focus: Health and Welfare Plans
"The [DOL] has made it clear, in no uncertain terms, that its sights are set on health and welfare plans for increased scrutiny going forward. [At a recent conference] the DOL reported that it is actively seeking out health and welfare plans across the country, examining Form 5500 filings, medical claims, prescription drug programs and plan documents."
(Lindquist LLP)
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Private Health Insurance Exchanges Demonstrate Their Business Value
"While insurer-led private exchanges have been touted as solutions that offer flexible options for employees and cost control for employers, the business case ... is evident in the data -- more than half (52 percent) of survey respondents reported seeing a reduction in administrative costs, and 48 percent have increased their market share. Reduced administrative costs can be significant, as they can offer extensive cost savings to employers, brokers and insurers by eliminating paper-based waste, errors and process inefficiencies."
(The Institute for HealthCare Consumerism [IHCC])
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Out-of-Pocket Maximums Steal the Show
"Beginning in 2016, no individual can pay more than $6,850 for in-network out-of-pocket expenses. That means any plan that has a family out-of-pocket maximum of more than $6,850 will need to include an individual out-of-pocket maximum within family coverage. And just to keep things interesting, remember that for HSA plans, all family members must contribute to the family deductible unless the individual deductible is at least $2,600. So many companies will be introducing plans with collective deductibles and individual out-of-pocket maximums for the first time."
(Frenkel Benefits)
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States with Stronger Health Insurance Rate Review Authority Experienced Slightly Lower Premiums in the Individual Market in 2010-13
"The [ACA] requires carriers in certain categories of health insurance to provide public justification for rate increases of 10 percent or more.... [A]djusted premiums in the individual market in states that had prior-approval authority combined with loss ratio requirements were lower in 2010-13 ($3,489) than premiums in states with no rate review authority or that had only file-and-use regulations, which gave the states no authority to block rate increases ($3,617). Adjusted premiums declined modestly in prior-approval states with loss ratio requirements, from $3,526 in 2010 to $3,452 in 2013, while premiums increased from $3,422 to $3,683 in states with no rate review authority or file-and-use regulations only."
(Health Affairs)
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New York Health Exchange Plans Get Average 7.1% Rate Increase, Ranging from 0.5% to 14%
"Health insurance premiums on New York's state-run exchange will go up by an average of 7.1% next year. But rates differ greatly by payer, plan type and region, highlighting the difficulties of relying on crude averages.... Oxford Health Plan enrollees will see their monthly premiums drop 12.3% in 2016, whereas people with Health Republic Insurance of New York will have to pay 14% more.... [T]he second-lowest-cost silver plans, which are the benchmark for setting the [ACA's] premium subsidies, will only increase by 0.5% next year in New York City."
(Modern Healthcare Online; free registration required)
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Benefits in General; Executive Compensation
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Being Prepared Can Make Independent CPA ERISA Audit Less Onerous (PDF)
"ERISA requires that certain ... [plan sponsors] must engage an Independent Qualified Public Accountant on behalf of the plan's participants to audit the plan financials prepared by the plan sponsor. This is generally referred to as an ERISA audit.... This column will briefly outline what you can expect when the auditor arrives, and some of the issues noted in the [AICPA] Audit Risk Alert."
(ERISAdiagnostics, Inc. via Thompson Pension Plan Fix-It Handbook)
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