compliance

compliance

Consolidated Appropriations Act 2021 | Part 3: Temporary Health FSA and DCAP Relief

Update 2/22/21: The Internal Revenue Service (IRS) issued Notice 2021-15 clarifying the relief provided under the Appropriations Act for health FSAs and DCAPs and provides additional cafeteria plan relief. The Consolidated Appropriations Act, 2021 (Appropriations Act), enacted on December 27, ...

Consolidated Appropriations Act 2021 | Part 2: Broker and Consultant Compensation Transparency, Prohibition on Gag Clauses

Broker and Consultant Compensation ERISA imposes penalties on prohibited transactions between covered benefit plans and individuals who have a relationship with the plan to ensure that these “parties in interest” do not use their influence with the plan for their own benefit or in a manner that ...

Consolidated Appropriations Act 2021 | Part 1: Congress Passes the No Surprises Act

The U.S. Congress has passed the Consolidated Appropriations Act, 2021 (Appropriations Act), which includes the No Surprises Act (Act), after contentious negotiation. As of the publication of this Advisor, President Trump has signaled that he will not sign the Appropriations Act into law until ...

Final Rules on Grandfathered Group Health Plan Coverage

In response the President’s Executive Order 13765 “Minimizing the Economic Burden of the Patient Protection and Affordable Care Act Pending Repeal” issued on January 20, 2017, the Department of Health and Human Services (HHS), Department of Labor (DOL), and the Department of the Treasury ...

Compliance Recap | November 2020

November was a relatively busy month in the employee benefits world. The U.S. Supreme Court (Supreme Court) heard oral arguments in the case of California v. Texas, which is the case challenging the constitutionality of the ACA. The Internal Revenue Service (IRS) released the updated ...

Blue Cross Blue Shield Tentative $2.67 Billion Antitrust Settlement

Blue Cross Blue Shield Association (BCBSA) has recently reached a tentative $2.67 billion settlement arising out of a class action lawsuit filed more than eight years ago by subscribers seeking injunctive and compensatory relief arising out of BCBSA’s alleged violation of federal antitrust ...

Proposed 2022 Benefit Payment and Parameters Rule

The Centers for Medicare & Medicaid Services (CMS) has released a proposed rule and fact sheet for benefit payment and parameters for 2022. CMS has also released its draft 2022 actuarial value calculator and draft 2022 actuarial value calculator methodology. According to CMS, the proposed ...

Highlights of the Patient-Centered Outcomes (PCORI) / Comparative Effectiveness Fee

The Patient-Centered Outcomes Research Institute (PCORI) fee initially applied from 2012 to 2019. However, in December 2019, the Further Consolidated Appropriations Act, 2020 extended the fee to 2029. The fee is due based on plan/policy years ending on or after October 1, 2012, and before ...

Frequently Asked Questions about the Patient-Centered Outcomes / Comparative Effectiveness Fee

You have a PCORI filing and payment obligation if: You sponsor a major medical self-insured health plan You sponsor a fully-insured health plan and a self-funded health reimbursement arrangement (HRA) You sponsor a health plan that meets minimum essential coverage only (MEC) Employer-sponsored ...

PCORI, TRF and HIP Fee Highlights

The IRS and the Department of Health and Human Services have issued final regulations that provide details on several fees that will be due as part of the Patient Protection and Affordable Care Act (ACA). Self-funded plans will calculate and pay these fees directly. Insurers will calculate and ...

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