 |
144 Turnpike Road Southborough, MA 01772 508-485-4000 |
News
Form W-2 Reporting of Group Health Plan Coverage
February 1, 2012 | SBA
On January 3, 2012, the IRS updated its guidance on the new health reform Form W-2 reporting requirement for employer-sponsored group health plan coverage. The new guidance appears in Notice 2012-09, and supersedes the W-2 reporting guidance issued last year in Notice 2011-28. This memorandum summarizes Notice 2012-09.
IRS clarifies Form W-2 Reporting Requirements for Employer-Sponsored Group Health Plan Coverage
January 4, 2012 | IRS
The IRS released new guidance on the health reform Form W-2 reporting requirements for employer-sponsored group health plan coverage. Last March, the IRS issued Notice 2011-28 discussing the W-2 reporting requirements in 31 questions and answers (Q&As). Notice 2012-9 supersedes the previous guidance and makes additional changes - the IRS clarified six of their previous Q&As and added eight new Q&As. Consequently, Notice 2012-9 now has 39 Q&As and becomes the most current guidance on the Form W-2 reporting requirements.
Preliminary Guidance on Essential Health Benefits
December 16, 2011 | HHS
HHS released preliminary guidance on Essential Health Benefits (EHB) - the benefits that must be covered by non-grandfathered health plans offered in the individual and small group markets both inside and outside the Exchanges. The guidance addresses only covered services - it doesn't address cost-sharing or the calculation of actuarial value. HHS notes that they intend to "release guidance on calculating actuarial value and the provision of minimum value by employer-sponsored coverage in the near future."
ERRP Coming to an End
December 9, 2011 | HHS
Based on the rate at which ERRP funds are being disbursed and the remaining amount of the $5 billion in appropriated funding, CMS will reject any claim list submitted in support of an ERRP reimbursement request that includes one or more claims with an incurred date of January 1, 2012 or later.
New FAQs Address SBC and Mental Health Parity Requirements
November 17, 2011 | DOL
The first question (Q&A-1) discusses the compliance date for the summary of benefits and coverage (SBC). Compliance with the SBC requirement will NOT be required until "final regulations are issued and applicable" and, in addition, that final regulations "will include an applicability date that gives group health plans and health insurance issuers sufficient time to comply." The remainder of the questions (Q&As 2-7) discuss the mental health parity requirements, focusing primarily on various scenarios involving nonquantitative treatment limitations.
CLASS Act Delayed....Perhaps Indefinitely
October 14, 2011 | HHS
Secretary Sebelius writes in a letter to Congress: "I do not see a viable path forward for CLASS implementation at this time."
Summary of Benefits and Coverage and Uniform Glossary Disclosure Requirements
August 25, 2011 | SBA
On August 22, 2011, the Departments of Health and Human Services, Labor and Treasury published proposed regulations on the health reform provision requiring group health plans and health insurance issuers to distribute two new disclosure documents: a Summary of Benefits and Coverage (SBC) and a Uniform Glossary of common terms.
Guidance on Complying with the Prohibition on Using Early Retiree Reinsurance Program Reimbursements as General Revenue
August 19, 2011
CMS guidance on the ERRP maintenance of contribution (MOC) requirement. The MOC requirement generally requires a plan sponsor to provide at least the same level of contribution (net of any ERRP reimbursements received) for plan years in the MOC compliance period as it did in an earlier year (or years) known as the baseline period.
Affordable Care Act Rules on Expanding Access to Preventive Services for Women
August 1, 2011 | HealthCare.gov
Additional health reform provisions requiring non-grandfathered group health plans to cover listed preventive care services at no cost sharing.
Change to Medicare Part D Creditable Coverage Notification Deadline
July 19, 2011
The Patient Protection and Affordable Care Act (PPACA) moved the Medicare Part D annual enrollment period to October 15th through December 7th. This effectively changes the date that notices of creditable coverage are due to October 15th.
February 1, 2012 | SBA
On January 3, 2012, the IRS updated its guidance on the new health reform Form W-2 reporting requirement for employer-sponsored group health plan coverage. The new guidance appears in Notice 2012-09, and supersedes the W-2 reporting guidance issued last year in Notice 2011-28. This memorandum summarizes Notice 2012-09.
IRS clarifies Form W-2 Reporting Requirements for Employer-Sponsored Group Health Plan Coverage
January 4, 2012 | IRS
The IRS released new guidance on the health reform Form W-2 reporting requirements for employer-sponsored group health plan coverage. Last March, the IRS issued Notice 2011-28 discussing the W-2 reporting requirements in 31 questions and answers (Q&As). Notice 2012-9 supersedes the previous guidance and makes additional changes - the IRS clarified six of their previous Q&As and added eight new Q&As. Consequently, Notice 2012-9 now has 39 Q&As and becomes the most current guidance on the Form W-2 reporting requirements.
Preliminary Guidance on Essential Health Benefits
December 16, 2011 | HHS
HHS released preliminary guidance on Essential Health Benefits (EHB) - the benefits that must be covered by non-grandfathered health plans offered in the individual and small group markets both inside and outside the Exchanges. The guidance addresses only covered services - it doesn't address cost-sharing or the calculation of actuarial value. HHS notes that they intend to "release guidance on calculating actuarial value and the provision of minimum value by employer-sponsored coverage in the near future."
ERRP Coming to an End
December 9, 2011 | HHS
Based on the rate at which ERRP funds are being disbursed and the remaining amount of the $5 billion in appropriated funding, CMS will reject any claim list submitted in support of an ERRP reimbursement request that includes one or more claims with an incurred date of January 1, 2012 or later.
New FAQs Address SBC and Mental Health Parity Requirements
November 17, 2011 | DOL
The first question (Q&A-1) discusses the compliance date for the summary of benefits and coverage (SBC). Compliance with the SBC requirement will NOT be required until "final regulations are issued and applicable" and, in addition, that final regulations "will include an applicability date that gives group health plans and health insurance issuers sufficient time to comply." The remainder of the questions (Q&As 2-7) discuss the mental health parity requirements, focusing primarily on various scenarios involving nonquantitative treatment limitations.
CLASS Act Delayed....Perhaps Indefinitely
October 14, 2011 | HHS
Secretary Sebelius writes in a letter to Congress: "I do not see a viable path forward for CLASS implementation at this time."
Summary of Benefits and Coverage and Uniform Glossary Disclosure Requirements
August 25, 2011 | SBA
On August 22, 2011, the Departments of Health and Human Services, Labor and Treasury published proposed regulations on the health reform provision requiring group health plans and health insurance issuers to distribute two new disclosure documents: a Summary of Benefits and Coverage (SBC) and a Uniform Glossary of common terms.
Guidance on Complying with the Prohibition on Using Early Retiree Reinsurance Program Reimbursements as General Revenue
August 19, 2011
CMS guidance on the ERRP maintenance of contribution (MOC) requirement. The MOC requirement generally requires a plan sponsor to provide at least the same level of contribution (net of any ERRP reimbursements received) for plan years in the MOC compliance period as it did in an earlier year (or years) known as the baseline period.
Affordable Care Act Rules on Expanding Access to Preventive Services for Women
August 1, 2011 | HealthCare.gov
Additional health reform provisions requiring non-grandfathered group health plans to cover listed preventive care services at no cost sharing.
Change to Medicare Part D Creditable Coverage Notification Deadline
July 19, 2011
The Patient Protection and Affordable Care Act (PPACA) moved the Medicare Part D annual enrollment period to October 15th through December 7th. This effectively changes the date that notices of creditable coverage are due to October 15th.