Health Plan Sponsors

News & Analysis as of

ACA Fees, and Forms, and Delays, Oh My!

In the latest round of delays under the Affordable Care Act (ACA), the Employee Benefits Security Administration recently announced that the deadline for health plans to provide enrollment information to the transitional...more

Survive The Season With Our Open Enrollment Checklist

It’s that time of year again, when fall weather brings with it a host of legal obligations for plan sponsors running open enrollment. Here’s what you need to know to survive the season....more

Front End Changes and, Again, More DIR Columns

Since the beginning of the Medicare Part D program, CMS has introduced many reporting mechanisms for trying to understand drug pricing, price concessions, and the cost of providing services to Part D members. The tool CMS...more

CMS Proposes Rule That Would Expand Its Authority To Audit Medicare Advantage Plans

On April 30, 2014, the Centers for Medicare and Medicaid Services (“CMS”) issued a proposed rule to update payment policies and rates for inpatient hospitals (the “Proposed Rule”) that includes a provision with significant...more

The Affordable Care Act—Countdown to Compliance for Employers, Week 33: The Impact of Value-Based–Plan Designs and Reference...

Whether a group health plan provides minimum value is central to the application of the Affordable Care Act’s employer shared responsibility rules. The particulars of the role of minimum value in determining assessable...more

New Guidance on COBRA and ACA Marketplace Coverage: The Gap in Coverage is (Not Quite) Filled

There has been much confusion and concern about the interplay between the COBRA continuation coverage rules and the new Health Insurance Marketplace established under the Affordable Care Act (the “Marketplace”). One important...more

How a Plan Sponsor Can Avoid Being a Deer Caught in the Headlights

The term “deer in the headlights” explains the mental state of a person who shows behavioral signs that remind us of a deer subjected to a car’s headlights where the deer is in such panic that they show no motor reaction to...more

Health Care Reform: Employer Reporting Requirements

Health care reform imposed new employer reporting requirements regarding health coverage provided to individuals, including: (i) reporting of minimum essential coverage for employer-sponsored self-insured plans and (ii)...more

IRS Releases Q&A on Elections and Reimbursements in Cafeteria Plans Post-DOMA

On December 16, the IRS released Notice 2014-1, providing additional guidance on administration of employee benefit plans in light of the Supreme Court’s June 26, 2013 decision in United States v. Windsor. Windsor invalidated...more

More Post-Windsor Guidance from the IRS Relating to Benefits for Same-Sex Spouses: Cafeteria Plan Changes, Flexible Spending...

Prior to the U.S. Supreme Court’s Windsor decision that repealed Section 3 of the federal Defense of Marriage Act (DOMA), same-sex spouses were not recognized as spouses for federal tax and benefits purposes. In the immediate...more

Year-End Compliance Reminders For Group Health Plan Sponsors

In 2013, many different changes in the law impacted group health plans and arguably, even more changes will occur in 2014. The following is an overview of a few of the key compliance issues that occurred in 2013 which should...more

CMS Issues Star Ratings for the 2014 Plan Year

On October 11, 2013, CMS posted the 2014 Medicare Health Plan Quality and Performance Ratings, which are commonly referred to as “Star Ratings.” CMS released the 2014 Star Ratings several days later than originally...more

Sponsors Of Group Health Plans Must Take Action To Comply With The Upcoming September 23, 2013 HIPAA Compliance Deadline

In January 2013, the U.S. Department of Health and Human Services (HHS) released final regulations which revised existing regulations under the Health Insurance Portability and Accountability Act (HIPAA). ...more

Business Associate Agreements: Time to Update

If you sponsor a group health plan that is subject to the HIPAA Privacy and Security Rules, it is time to review and potentially update your business associate agreements....more

Extension of Participant Fee Disclosure Deadline Is Available for 2013 or 2014

The Department of Labor has provided plan administrators with a one-time opportunity to delay annual distribution of investment information to retirement plan participants for up to 6 months in 2013 or 2014....more

Okay For Health Plan To Cover Same Sex But Not Opposite Sex Domestic Partners

I have always been interested in the intersection of employment law and benefits law....more

Final Rules on Wellness Programs under the Affordable Care Act

Plan sponsors should review wellness programs for compliance with recently issued final rules, which among other things increase the maximum permissible award for certain wellness programs. On May 29, the Internal Revenue...more

Revised IRS Form 720, Updated For Reporting Patient-Centered Outcomes Research Institute (PCORI) Fees, Now Available: Due By July...

The Affordable Care Act (the ACA) established the Patient-Centered Outcomes Research Institute (the Institute) in order to provide comparative clinical effectiveness research data so that patients, health care providers,...more

CMS Medicare MLR Final Rule Creates New Obligations and Risks

The Centers for Medicare & Medicaid Service’s release of the final Medicare medical loss ratio regulations allows Medicare Advantage Organizations and Part D Plan Sponsors to evaluate their operations in order to come into...more

A Self-Funded Employer’s Worst Nightmare

Employers who sponsor health plans for their employees can purchase insurance contracts to fund those plans. Alternatively, employers can self-fund or self-insure those benefits, agreeing to pay the claims themselves....more

OIG Revises Special Advisory Bulletin on Exclusions

OIG continues its aggressive interpretation of scope and effect of exclusion from participation in Federal health care programs and clarifies several open questions....more

May and June Filing and Notice Deadlines for Qualified Retirement and Health and Welfare Plans

Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties and excise taxes. To...more

Let the Seller Beware: Hospitals Treating HMO Patients Employed by the Federal Government are “Subcontractors” Governed by...

When a health plan/HMO ("Plan") provides group health coverage to employers, including the federal government, the hospitals that treat federal employees under a contract with the Plan are government "subcontractors" subject...more

Affordable Care Act: New Requirements for Summary of Benefits and Coverage

The Departments of Labor, Treasury, and Health & Human Services have issued new guidance on the content requirements for health plan summaries of benefits and coverage (“SBCs”). Plan sponsors should ensure that the SBCs...more

Supreme Court Clarifies Subrogation Rights, Emphasizes Need for Precise Plan Language

Plan sponsors, particularly those that sponsor self-funded health plans, should review plan document provisions in light of the recent decision of the Supreme Court of the United States in US Airways, Inc. v. McCutchen. In...more

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