
Articles
Procuring Developer-Oriented Surety Bonds
Tuesday, October 7, 2014
At a recent construction industry event, a developer asked me why surety bonds have become so much harder for him to procure than in the past. The bonds he was referring to are bonds for things such as erosion control, storm water & drainage, grading & clearing, wetlands mitigation, landscaping and right of way, among others. He knew that reputation, work history and financial position all influenced qualification for surety bonds. But beyond qualifying one’s character, capacity and capital – three key components used in the surety qualification process – perhaps the biggest X factor is the number of surety markets willing to entertain developer-oriented surety.
PCORI Fee Increase
Monday, September 29, 2014
In Notice 2014-56, the IRS provided the new amount for the Patient-Centered Outcomes Research (PCORI) fees for plan years ending after Sept 30, 2014 and before Oct 1, 2015. The fee for such plan years is $2.08 (up from $2) multiplied by the average covered lives for the plan year. The carriers/insurers will pay the fee on behalf of fully-insured plans, but self-funded plans are responsible for paying the fee on behalf of any applicable group health plans.
Section 125 Rules to Recognize Two New Permitted Election Changes
Wednesday, September 24, 2014
Last Thursday, the IRS released guidance regarding current Section 125 rules that is likely to be well-received by most employers. The guidance permits two new permitted election changes (prospective revocations) to correspond with some unintended consequences created under the employer shared responsibility rules under Section 4980H and new coverage options available through the public Marketplace (Exchange).
Medicare Part D Notice Reminder: Deadline of October 14th
Tuesday, September 16, 2014
As you may recall, with the introduction of Medicare Part D prescription drug benefits, the Centers for Medicare and Medicaid Services (CMS) imposed certain notice requirements on employers. Employers are required to notify all Medicare beneficiaries of the “creditable” or “non creditable” coverage status of their prescription drug plan.
IRS Releases ACA Employer Reporting Instructions
Monday, September 8, 2014
The IRS has released draft instructions for the employer health plan reporting requirements contained in the Affordable Care Act (ACA). Applicable large employers, and small employers who offer self-funded plans, now have the information they need to start planning for the required reporting beginning in 2016 for 2015 health
Supreme Court Supports Innovation
Friday, August 1, 2014
In what amounts to good news for technology innovators, the Supreme Court ruled on behalf of CLS Bank in their suit brought against Alice Corporation.
How Employers Should Handle MLR Rebates
Thursday, July 31, 2014
For the third year, employers who sponsor an insured group health plan may be receiving a Medical Loss Ratio (MLR) rebate from their insurers.
PCORI Fees due July 31
Wednesday, July 16, 2014
Employers who sponsor self-funded medical plans must report and pay the ACA Patient-Centered Outcomes Research Institute (PCORI) fees no later than July 31, 2014. Health insurance carriers/insurers will pay the fee directly in the case of fully-insured plans.
Final Rules – 90 Day Waiting Period & Orientation Period
Wednesday, July 9, 2014
Final regulations were released by the Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury (IRS) (The Departments) regarding the Affordable Care Act (ACA) 90-day waiting period rules, including the new, one month “orientation period”, which may be imposed prior to the start of the waiting period.
Background
What the Supreme Court Hobby Lobby Case Means to Employers
Tuesday, July 8, 2014
In a 5 to 4 decision, the Supreme Court has ruled that certain privately held corporations do not have to comply with some of the Affordable Care Act’s (ACA) contraception coverage requirements if they violate the owner’s religious views. The decision opens the door for companies that meet the IRS definition of a “closely held corporation” to opt-out of providing certain contraception coverage in their employer sponsored group health plan.
Self-funded Employers and the HIPAA Health Plan Identifier Number (HPID)
Monday, May 12, 2014
The Department of Health and Human Services (HHS) has issued guidance regarding HIPAA electronic transactions related to the HIPAA privacy and security rules. According to the guidance, employers who sponsor self-funded health plans will be required to take certain administrative steps, including applying for a health plan identifier number (HPID) and getting certification from certain vendors that they are in compliance with HIPAA transaction rules.
Special Open Enrollment Offered to COBRA QBS and New ACA FAQs and COBRA Model Notices Released
Thursday, May 8, 2014
New FAQs, released by the Department of Labor (DOL), Health and Human Services (HHS), and the Treasury (IRS), clarify certain requirements in regard to the annual out-of-pocket maximum, coverage for preventive services, health FSA carryover, and summary of benefits and coverage (SBC). Also, in states with the Federally-facilitated Marketplace, individuals currently on COBRA have been offered a special one-time open enrollment period.
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