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Health Care Reform Updates
Health Care Reform News!
Banyan Consulting LLC is pleased to present our new Health Care Reform series. Over the next months and years, employers will be faced with numerous changes, many of which require regulatory clarification. We'll use this venue to keep you up to date, and on target with decisions that affect your plans.
- 6/1/12 - New Health Care FSA Maximum Start Date By: Brian Elinich, Consultant;One of the provisions of the Patient Protection and Affordable Care Act (PPACA) is a limit on the amount an individual can contribute tax-free towards a health care flexible spending account (HCFSA). The new maximum contribution amount of $2,500 is to go into effect...
- 5/29/12 - Health Care Reform Update Comparative Effectiveness Research Fee On April 17th, the Internal Revenue Service (IRS) issued proposed rules for collecting a comparative effectiveness research fee from plan sponsors of self-funded health plans. The proposed rules are in response to comments the IRS received after issuing IRS Notice 2011-35 in June, 2011.
- 3/27/12 - New Oral Contraceptive Safe Harbor On February 10, 2012, the Department of Health and Human Services (HHS) announced a temporary enforcement safe harbor for certain entities to comply with the health care reform provision requiring coverage for oral contraceptives with no participant cost-sharing.
- 8/23/11 - Health Care Reform Enhanced Womens Preventive Services On 8/1/2011, the DOL issued Interim Final Rules on Enhanced Women’s Preventive Services resulting in considerable media coverage particularly concerning oral contraceptives now being payable with no cost share, such as a copay.
- 6/9/11 - Health Care Reform Repeal of Free Choice Voucher Provision The Free Choice Voucher requirement is the second PPACA provision (expanded 1099 Form Reporting Requirement, the first) to be repealed, to date.
- 4/15/11 - Health Care Reform W2 Reporting Interim Final Rules On March 31, 2011, the Internal Revenue Service (IRS) released the 19-page Interim Final Rules on the Health Care Reform W-2 reporting requirements. The IRS is still taking comments on the rules for the next 60 days.
- 1/14/11 - Health Care Reform Cadillac Tax Another component of the Patient Protection and Affordable Care Act (PPACA) commonly referred to as the Health Care Reform Act is a tax on benefit-rich or “gold-plated” insurance plans. This tax is often referred to as “The Cadillac Tax” and, although it is not scheduled to go into effect until 2018 and may see several revisions in design before then, some plan sponsors are beginning to develop strategies to address it.
- 1/5/11 - Over-The-Counter Medicine Reimbursement and Non-discrimination Testing for Insured Plans On December 23, 2010, the Internal Revenue Service (IRS) issues two notices, 2011-5 and 2011-1, revising administrative rules for two health care reform provisions: Over-The-Counter Medicine Reimbursement and Non-discrimination Testing for Insured Plans.
- 11/1/10 - Health Care Reform Medicare Arguably the greatest volume of reforms through the Patient Protection and Affordable Care Act (“Affordable Care Act”) signed into law on 03/23/2010 involve Medicare. Some of the provisions are direct reforms to Medicare while other provisions of the Affordable Care Act may have an indirect, but intentional, impact on the program.
- 10/25/10 - Health Care Reform Small Business Tax Credit One of the principal objectives of the Health Care Reform Act signed into law on 3/23/2010 was to make health care coverage available to more people. One of the primary means to accomplishing this goal was to encourage small businesses to begin, or continue, providing health care coverage for their employees. To assist small business in achieving this objective, significant tax credits are being offered beginning with the 2010 tax year.
- 10/14/10 - Health Care Reform W-2 Reporting Another component of the Health Care Reform Act signed into law on 3/23/2010 is that beginning with the 2011 tax year, employers must report the aggregate cost of applicable employer-sponsored health insurance coverage on employees W-2 forms. General information about this requirement has been provided, however, the Department of Labor (DOL) has not yet issued Interim Final Rules on this provision of the Health Care Reform Act.
- 9/30/10 - Health Care Reform Lifetime and Annual Limits The Patient Protection and Affordable Care Act (“Affordable Care Act”) signed into law on 03/23/2010 includes changes to any limits on the benefit amount payable on a per participant basis by an employer-sponsored group health plan. These provisions take effect on the first day of the first plan year following 9/23/2010. Lifetime limits on a per participant basis will be prohibited. Annual limits on a per participant basis will still be permitted on a restricted basis until 2014 when those, too, are prohibited.
- 8/18/10 - Health Care Reform Preventive Services One component of the Health Care Reform Act signed into law on 3/23/2010 requires minimum coverage, without employee cost-sharing, for services rated A or B by the US Preventive Services Task Force. What You Need to Know Now About: Preventive Services
- 8/4/10 - Health Care Reform Bulletin - OTC Medicine Reimbursement What You Need to Know Now About: Over-the-Counter (OTC) medicine reimbursement through a Flexible Spending Account (FSA), Health Reimbursement Account (HRA) or Health Savings Account (HSA)
- 7/19/10 - Health Care Reform Bulletin - Disclosure Notices - Sample Language - Part 1 Over the past few weeks, the Department of Labor (DOL) has provided sample language for plan sponsors to use in disclosing Health Care Reform changes to plan participants. This HCR Update focuses on the model notices provided by the DOL on The Grandfather Clause, Dependent Coverage to Age 26, Lifetime Limits and Patient Protection.
- 6/29/10 - Health Care Reform 2013 to 2018 In an effort to help employers address their long-term questions and concerns, we have developed our Phase II report “Health Care Reform Legislation: What employers need to consider for 2013-2018.” This report will provide, in plain language, the Who, What and When of the new legislative provisions.
- 6/23/10 - Health Care Reform Bulletin Grandfather Clause Under the Health Care Reform law, existing, or “grandfathered” health plans are exempt from several consumer protections in the law that are going into effect for new plan years beginning after 9/23/2010. This Health Care Reform Bulletin defines “grandfathered” health plans and addresses different portions of the provision including how to keep your plan’s grandfathered status.
- 6/3/10 - Health Care Reform Bulletin - Early Retiree Reinsurance Program One of the pieces in the Health Care Reform Act that will take effect in the very near future is the program being established for early retiree reinsurance. The Department of Health and Human Services (HHS) recently issued an interim final rule that provides additional details. This Health Care Reform Bulletin addresses different portions of the provision and how it impacts early retiree group health plan sponsors.
- 5/13/10 - Health Care Reform Bulletin - Dependent Children There are a few different pieces in the Health Care Reform Act that take effect in the near future. The one that has garnered more headlines is the requirement to cover dependent children to age 26. This Health Care Reform Bulletin addresses different portions of the provision and how it impacts employers.
- 4/7/10 - Health Care Reform 2010 to 2012 What Employers Need to Consider for 2010-2012