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[Official Guidance]

Text of Draft 2019 Instructions for IRS Forms 1094-C and 1095-C (PDF)

18 pages; Nov. 13, 2019. "An ALE Member must file one or more Forms 1094-C (including a Form 1094-C designated as the Authoritative Transmittal, whether or not filing multiple Forms 1094-C), and must file a Form 1095-C for each employee who was a full-time employee of the ALE Member for any month of the calendar year. Generally, the ALE Member is required to furnish a copy of the Form 1095-C (or a substitute form) to the employee." [Also available: Draft 2019 Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, and Draft 2019 Form 1095-C, Employer-Provided Health Insurance Offer and Coverage]

Internal Revenue Service [IRS]


Early Registration for HBCE Is Ending December 19

Sponsored by International Foundation of Employee Benefit Plans [IFEBP]

Start 2020 off right and get the knowledge you need at the 29th Annual Health Benefits Conference & Expo (HBCE). Hear from leading organizations and learn from experts about trends, critical issues and best practices. Register by December 19 to save! Learn more

[Official Guidance]

Text of Draft 2019 Instructions for IRS Forms 1094-B and 1095-B (PDF)

8 pages; Nov. 13, 2019. "Every person that provides minimum essential coverage to an individual during a calendar year must file an information return reporting the coverage.... Employers (including government employers) subject to the employer shared responsibility provisions sponsoring self-insured group health plans generally will report information about the coverage in Part III of Form 1095-C instead of on Form 1095-B. However, employers that offer employer-sponsored self-insured health coverage to non-employees who enroll in the coverage may use Form 1095-B, rather than Form 1095-C, Part III, to report coverage for those individuals and other family members." [Also available: Draft 2019 IRS Form 1094-B, Transmittal of Health Coverage Information Returns, and Draft 2019 IRS Form 1095-B, Health Coverage]

Internal Revenue Service [IRS]

[Guidance Overview]

Agencies Issue New SBC Template and Related Materials for 2021

"Unlike the last update of SBC materials, these items were not circulated in proposed form before finalization.... Note that, although the individual mandate payment has been eliminated beginning in 2019, the new template is only for use beginning with the 2021 plan year. The new materials do not address this issue, nor do they address in any more detail the challenges of completing SBCs for account-based plans or specify whether the agencies will apply a 'good faith' standard for compliance with the SBC requirement (as they did initially)."

Thomson Reuters / EBIA

[Guidance Overview]

Annual Adjustment Leads to Uncertainty in HIPAA Penalty Maximums

"Under the April Notice, [HHS] determined that the calendar year cap should vary based on the level of culpability ... [and] noted that the revised tiered calendar year caps would be utilized by the Department until further notice ... [HHS] has legal standing to rely on the amounts identified in the 2019 Inflation Rule. However, it is unlikely that [HHS] will, without notification, rescind the tiered structure approach adopted under the April Notice."

Holland & Knight

[Guidance Overview]

Editor's Pick Applicability of Federal Requirements to Selected Health Coverage Arrangements (PDF)

29 pages. "[N]ot all private health coverage arrangements comply with [federal requirements, including] 'exempted health coverage arrangements' and 'noncompliant health coverage arrangements' ... This report identifies and describes arrangements within these two categories. It is intended to help congressional policymakers better understand the scope of such arrangements available to individuals in the United States and to provide information about the limits of the application of federal health insurance requirements." [R46003 Nov. 13, 2019; also published by the Congressional Research Service: An Overview]

Congressional Research Service [CRS]

[Guidance Overview]

Do You Remember the HPID Requirement? Good, Now You Can Forget It

"HHS will automatically deactivate all HPIDs and OEIDs on December 27, 2019 and notify the designated contacts in the Health Plan and Other Entity Enumeration System (HPOES), which was the system used to obtain HPIDs and OEIDs. HPOES will remain open until February 25, 2020 for plan sponsors and other entities to view and record information about their HPID and OEID."

Miller Johnson

Editor's Pick Florida Class Actions Show Why Correct COBRA Notices Matter (PDF)

"Each [of the dozen lawsuits] asserts that the COBRA election notice did not comply with one or more of the notice requirements, i.e., that the notice 'partially adhered to' portions of the nonmandatory model notice in the COBRA regulations but that 'critical parts are omitted or altered in violation' of the regulations... Plan sponsor employers are not insulated from these suits even if there is a separate third-party COBRA administrator."

McDermott Will & Emery

Employer Health Insurance Prices Expected to Go Up About 5 Percent in 2020

"The largest employers ... are becoming ever more serious about obtaining lower prices, even if that means opening on-site health care clinics or contracting with certain 'centers of excellence' for certain high-cost services such as heart surgery.... Companies are also getting creative with 'carve outs' a term that refers to services that are covered immediately without employees having to pay their deductibles first. Certain services, companies are beginning to realize, can end up paying off in the long run if they prevent more expensive services down the road."

The San Diego Union-Tribune

Editor's Pick Expanding Payer and Provider Participation in Data Exchange: Options for California (PDF)

33 pages. "This issue brief lays out a spectrum of policy, contracting, and financing levers available to states as they consider how to support interoperability. It reviews other states' experiences and extracts lessons from their successes and failures that can inform California's future."

California HealthCare Foundation

Benefits in General

[Official Guidance]

Text of IRS Rev. Proc. 2019-14: Updated Guidance for Deductible Business, Charitable, Medical and Moving Expenses (PDF)

"This revenue procedure provides rules for using optional standard mileage rates in computing the deductible costs of operating an automobile for business, charitable, medical, or moving expense purposes.... This revenue procedure also provides rules for substantiating ... the amount of an employee's ordinary and necessary expenses of local travel or transportation away from home that a payor (an employer, its agent, or a third party) reimburses using a mileage allowance."

Internal Revenue Service [IRS]

Press Releases

Valerie Sinicrope Earns CRPS Designation by CFFP
Steidle Pension Solutions, LLC, [SPS]

Most Popular Items in the Previous Issue, Inc.
1298 Minnesota Avenue, Suite H
Winter Park, Florida 32789
(407) 644-4146

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 2019, Inc. All materials contained in this newsletter are protected by United States copyright law and may not be reproduced, distributed, transmitted, displayed, published or broadcast without the prior written permission of, Inc., or in the case of third party materials, the owner of those materials. You may not alter or remove any trademark, copyright or other notices from copies of the content.

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