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[Guidance Overview]
Proposed 2018 Notice of Benefit and Payment Parameters: Part 1
"The proposed rule, preface, and analyses come in at under 300 pages ... Most of the proposals will not go into effect until 2018 or later years, but a few are intended to take effect already in 2017 and a number build on initiatives already underway. The clear focus of the proposed rule is to strengthen and improve the marketplaces."
Timothy Jost, in Health Affairs
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[Guidance Overview]
Error Messages and the ACA: A Practical Guide to Handling Missing and Incorrect TINs
"Because penalties for failures to report correct information increase as time goes on, it is recommended that you conduct a second solicitation ... sooner rather than later. If a TIN is incorrect but you have engaged in the [prescribed] solicitation procedure, you may be successful in having the penalties waived because you acted in a reasonable manner.... [If] you reported no TINs for employees on ACA forms, you should make the first annual solicitation by October 12, 2016. If you do not receive a TIN after that solicitation, you have to solicit the TIN again by December 31, 2017 to show reasonable cause."
Fisher Phillips
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Innovations in Employee Engagement in Health (PDF)
12 pages. "This ... article summarizes discussion on how employers are trying to increase individuals' involvement in health -- and why it's important, presented at the Employee Benefit Research Institute's 78th policy forum in Washington, DC, on May 12, 2016. The topic was 'Innovations in Employee Engagement in Health' and brought together about a hundred benefits-related experts to discuss a variety of health and retirement topics."
Employee Benefit Research Institute [EBRI]
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Call Me Maybe? Telemedicine ROI
"Telehealth saves an average of $100 a visit, assuming an office visit costs $140 and a telehealth visit costs $40 ... Comparing a telemedicine visit for a minor ailment to an in-person visit, [one] vendor, reports it achieves an average savings of $673 per claim.... [One employer] saved about $192,000 since implementing telehealth, based on an average ER visit costing $1,233 average, urgent care visits at $150 and an e-visit average cost of $50."
International Foundation of Employee Benefit Plans [IFEBP]
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Ohio Association to Offer Self-Funded Health Plan as MEWA for Small Businesses
"The Council of Smaller Enterprises (COSE) soon will offer a self-funded, multiple-employer health plan for small businesses through a contract with Medical Mutual of Ohio. COSE received approval from the Ohio Department of Insurance to sponsor the new option. COSE's current fully-insured plans through Medical Mutual are still available. The COSE Health and Wellness Trust ... is a Multiple Employer Welfare Arrangement (MEWA) that brings together businesses with 50 or fewer employees, including sole proprietors, to self-fund their health plans."
Crain's Cleveland Business
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An Examination of Relative Risk in the ACA Individual Market (PDF)
30 pages. "Increased risk scores may be a combination of identification through better coding as well as a measure of the actual population health. Some states and issuers had significant swings in average risk measures, in both direction and magnitude. State variability due to underlying market characteristics means that national summary risk measures do not adequately represent the experience. The program is still too immature to draw conclusive inferences about the future of the pool or marketplaces."
Society of Actuaries
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Watchdog Group Says HHS May Have Bilked Taxpayers
"The funds were collected under a provision of the [ACA], which established a reinsurance program for high-risk individuals. Insurance providers and third-party administrators of group health plans all paid into it. By law, these funds were supposed to go to both insurance plans that take on more high-risk individuals and to the Treasury. Yet when the government took in less money than projected, HHS appears to have taken about $5 billion earmarked for the Treasury and given it to insurance companies instead. Critics charge that this is a government bailout of the insurance industry[.]"
American Media Institute
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Benefits in General
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[Guidance Overview]
Current Issues Affecting Pension Plan 401(h) Accounts (PDF)
"Section 401(h) account overfunding has given rise to numerous issues for plan sponsors.... Recent developments in financial accounting may affect plan sponsors with 401(h) accounts, too. [The authors] briefly discuss both topics ... and recommend that affected plan sponsors work with legal counsel to identify reasonable approaches to maximize the use of 401(h) account assets consistent with the limited guidance currently available."
Groom Law Group
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ERISA Advisory Council to Meet Sept. 27 by Phone
"[T]he 183rd open meeting of the Advisory Council on Employee Welfare and Pension Benefit Plans (also known as the ERISA Advisory Council) will be held as a teleconference on September 27, 2016.... The purpose of the open meeting is to discuss reports/recommendations for the Secretary of Labor on the issues of [1] Cybersecurity Considerations for Benefit Plans and [2] Participant Plan Transfers and Account Consolidation for the Advancement of Lifetime Plan Participation."
Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL]
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Executive Compensation and Nonqualified Plans
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Recent SEC Enforcement Actions Prompt Consideration of Whistleblower Carve-Outs
"The terms of recent settlements should serve as reminder to any company that falls within the SEC's enforcement jurisdiction (a significantly broader group that just public companies) to consider including provisions in severance and confidentiality agreements to explicitly provide that an employee may communicate with the SEC (and other federal agencies) about potential securities law violations without company approval (notwithstanding other confidentiality and disclosure obligations in the agreement)."
Dodd-Frank.com, a blog by Stinson Leonard Street
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Press Releases
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BenefitsLink.com, Inc.
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Lois Baker, J.D., President
David Rhett Baker, J.D., Editor and Publisher
Holly Horton, Business Manager
BenefitsLink Health & Welfare Plans Newsletter, ISSN no. 1536-9595. Copyright 2016 BenefitsLink.com, Inc. All materials
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