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17 results with the tag “Benefits & Healthcare Update”

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Benefits & Healthcare Update: IRS Reminds Employers That Certain Nonmedical Wellness Incentives Are Taxable Income

12 July 2016

The IRS recently released a memorandum reminding employers about the tax treatment of wellness program incentives and employer reimbursement of wellness program-specific premiums. While the memorandum did not break any new ground, it is a useful recap of the IRS rules regarding the taxability of wellness incentives.

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Benefits & Healthcare Update: Departments Release New Guidance on ACA Cost Sharing Limits, HSA Rules

4 May 2016

On Friday April 29, 2016, the Internal Revenue Service (IRS) released HSA contribution rules and HSA-eligible HDHP plan design rules for the 2017 plan year. Previously, the Department of Health and Human Services (HHS) released proposed rules for the out-of-pocket maximum limits applicable to non-grandfathered health plans under the ACA. Remember, there are two sets of rules post-ACA: one regarding out-of-pocket maximum limitations for non-grandfathered group health plans under the ACA, and another set of rules for Health Spending Accounts (HSAs) and HSA-qualifying High Deductible Health Plans (HDHPs) under the Internal Revenue Code. Out-of-pocket Maximum Limitations under ACA For non-grandfathered group health plans, out-of-pocket maximums cannot be greater than $7,150 for single coverage and $14,300 for non-single/family coverage for the 2017 plan year.

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Benefits & Healthcare Update: Church Plan Exemption from ERISA Does Not Apply to Religiously-Affiliated Hospital

31 March 2016

On March 17th, the Seventh Circuit Court of Appeals published the second appellate opinion concluding that plans established by religiously affiliated employers, including hospitals, do not enjoy the church plan exemption from ERISA because the plan was not established by a church. Since the church plan exemption does not apply to these plans, the plans must meet ERISA's requirements regarding plan documentation, filing, legal protections, and appeal procedures. This Seventh Circuit opinion follows much the same reasoning as the first decision on this subject that was handed down by the Third Circuit in December 2015: by the terms of the statute, the exemption from ERISA only applies to plans established by churches themselves, not to plans established by church-affiliated organizations.

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Benefits & Healthcare Update: IRS Increases Affordability Safe Harbors, Clarifies Treatment of Waiver Incentives

13 January 2016

At the end of 2015, the Internal Revenue Service (IRS) provided guidance in Notice 2015-87 with respect to Health Reimbursement Accounts (HRAs) and how to calculate the affordability of coverage. While much of the guidance restates and formalizes previous remarks from the agency, there are a couple new developments in the Notice regarding affordability that can affect the way employers set their employee contributions and structure their plans. Affordability Safe Harbors Indexed In the Final Rule regarding the employer mandate, the IRS established three safe harbors for providing affordable medical insurance to ACA full-time employees: the Federal Poverty Level safe harbor, the Form W-2 safe harbor, and the Rate of Pay safe harbor.

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Benefits & Healthcare Update: IRS Pushes Back Due Date for Form 1095-C to March 31, 2016

29 December 2015

On Monday, December 28th, the Internal Revenue Service (IRS) published Notice 2016-4 announcing transitional relief for health insurance information reporting: Forms 1095-C are now due to individuals by March 31st, 2016 and to the IRS, along with the Form 1094-C, by June 30th, 2016 when filing electronically. This welcome reprieve allows employers and other filing entities more time to establish systems for generating and completing the Forms. Notice 2016-4 can be found on line here: https://www.irs.gov/pub/irs-drop/n-16-4.pdf If you have any questions about health insurance information reporting, please contact Ed Doherty at 646-839-8251 or via email at EDoherty@cammackhealth.com.

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Benefits & Healthcare Update: Congress Will Delay Cadillac Tax for Two Years

17 December 2015

Congress is expected to pass a year-end budget deal for 2016 that delays levying the tax on high cost health insurance, known as the Cadillac Tax, until 2020. The deal also includes tax delays on medical devices and health insurers, as well as other provisions affecting health insurance and employee benefits generally. Cammack Health will release another Alert once the budget deal becomes law and more details are known. If you have any questions about the Cadillac Tax, please contact Ed Doherty at 646-839-8251 or via email at EDoherty@cammackhealth.com.

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Benefits & Healthcare Update: Agencies Finalize ACA Market Reform Rules, Make No Substantial Changes

4 December 2015

On November 18, 2015, the DOL, HHS, and IRS jointly published final rules on grandfathered plan status, pre-existing condition exclusions, lifetime and annual limits, rescissions, dependent coverage, appeals, and patient protections. The final rules formalize and merge the previously issued interim rules and sub-regulatory guidance.

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Benefits & Healthcare Update: EEOC Issues Rules for Wellness Plans Offering Incentives for Dependent Participation

10 November 2015

On Friday, October 30th, the Equal Employment Opportunity Commission (EEOC) published proposed rules for how wellness programs can provide incentives for spouses to participate without violating the Genetic Information Nondiscrimination Act (GINA). The proposed rules make clear that a wellness plan may offer incentives for a spouse to complete a medical examination, a Health Risk Assessment (HRA), or similar medical questionnaire. Under the proposed rules, a wellness plan may offer an incentive to an employee whose spouse (1) is covered under the employee's health plan; (2) receives health or genetic services offered by the employer, including as part of a wellness program; and (3) provides information about his or her current or past health status as part of a HRA.

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Benefits & Healthcare Update: New York City Ordinance Requires Employers to Offer Pre-Tax Transit Benefits

9 November 2015

Effective January 1, 2016, New York City Local Law 53 will require all employers with more than 20 full-time employees to offer all full-time workers the opportunity to use pre-tax earnings to purchase qualified transportation fringe benefits under Section 132(f) of the Internal Revenue Code. Although the law is effective January 1, 2016, employers will not be subject to any penalties for violating the law until July 1, 2016. After that date, any employer that has violated the law will have 90 days to cure their first violation.

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Benefits & Healthcare Update: Affordable Care Act's Automatic Enrollment Requirement Repealed

9 November 2015

The "automatic enrollment" provision of the Affordable Care Act, never enforced, has been repealed under the Bipartisan Budget Act of 2015, signed by President Obama on November 2, 2015. As written in the 2010 ACA legislation, the automatic enrollment provision required employers that are subject to the Federal Labor Standards Act (FLSA) and which employed more than 200 full-time employees to automatically enroll new full-time employees in one of the employer's health plans, subject to any waiting period authorized by law. Notices would have been required giving employees an opportunity to opt out of any coverage in which the employee was automatically enrolled.

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Benefits & Healthcare Update: IRS Publishes Updated Health FSA Contribution Limit, Qualified Transportation Amounts

9 November 2015

On Thursday, October 21st, the Internal Revenue Service (IRS) published in Revenue Procedure 2015-53 increases to amounts that adjust annually for inflation, including the contribution limit for health Flexible Spending Accounts (FSA) and the pretax limits for certain Qualified Transportation Fringe Benefits. For 2016, the limitation on employee contributions to health FSAs remains $2,550, the same as 2015. The 2015 monthly pretax limitation for transportation in a commuter highway vehicle and mass transit also remains the same as 2015, $130.

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Benefits & Healthcare Update: IRS Publishes Final 2015 Instructions for Health Insurance Information Reporting

1 October 2015

On September 18, 2015, the Internal Revenue Service (IRS) published the final 2015 instructions for completing Forms 1094-C and 1095-C. The 2015 instructions clarify the reporting of multiemployer plan coverage, make a substantive change in the manner in which offers of COBRA coverage are reported, and clarify how employers report HRA coverage paired with insured medical benefits.

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Benefits & Healthcare Update: Departments Release New Guidance on ACA Cost Sharing Limits, HSA Rules

6 May 2015

The Department of Health and Human Services (HHS) and the Internal Revenue Service (IRS) recently released plan design rules for the 2016 plan year. The biggest change is the clarification of how out-of-pocket maximum limitations work under the Affordable Care Act (ACA): non-single coverage limits "embed" the single coverage limit in the sense that an individual cannot owe pay more than the single limit regardless of whether the individual has single coverage or is a member in non-single coverage. Remember, there are two sets of cost sharing rules post-ACA: one regarding out-of-pocket maximum limitations for all large group health plans under the ACA, and another set of rules for Health Spending Accounts (HSAs) and HSA-qualifying High Deductible Health Plans (HDHPs) under the Internal Revenue Code.

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Benefits & Healthcare Update: EEOC Proposes Wellness Regulations, Adding Regulatory Limits to Program Design

22 April 2015

On April 20, 2015, the Equal Employment Opportunity Commission (EEOC) published proposed regulations for keeping employer-maintained wellness programs compliant with the Americans with Disabilities Act (ADA). This is welcome guidance after litigation brought by the EEOC sparked discourse over wellness programs last year.

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