Entries by Anna Mulder

Good News for Employers Who Sponsor HRAs!

Final ACA Instructions Provide Reporting Relief to HRAs Integrated with Health Plans.   The Final Instructions for ACA reporting forms 1094-B and 1095-B were issued yesterday, and provide clarification and relief to employers who sponsor a Health Reimbursement Arrangement (HRA).   Background: The rules seemed to keep changing about HRA reporting, adding even more complexity to a reporting obligation […]

HRAs are still alive!

On September 13, 2013, The Department of Treasury (IRS) and Department of Labor (DOL) released yet more guidance called The “Application of Market Reform and other Provisions of the Affordable Care Act to HRAs, Health FSAs, and Certain other Employer Healthcare Arrangements”. IRS Notice 2013-54 (which has substantially the same text as contained in the DOL release) addressed three […]

Do you know if your company is subject to the new ACA reporting requirements?

The Affordable Care Act (ACA) impacts nearly every business and individual in the U.S.  Two major components of the ACA are the individual mandate and the employer mandate.  In order to enforce or administer these mandates, the government is requiring employers providing minimum essential coverage to report certain information to the IRS about the coverage […]

PCORI Filing Requirements for HRAs

Patient-Centered Outcomes Research Institute (PCORI) Fees Apply To Employers Who Sponsor HRAs (And Some FSAs)   If you are an employer who sponsors a plan that reimburses or pays health expenses of your employee (a Health Reimbursement Arrangement, aka HRA) then we are talking to you!   Background: The Affordable Care Act (ACA) created a […]

Can Physician “Concierge Fees” be Reimbursed From a Health FSA or HSA?

As “concierge medicine” gains popularity, we are getting a lot of inquiries as to whether such fees can be reimbursed from a Health FSA or HSA.  The answer is not always clear.   What is Concierge Medicine? Concierge medical practices provide a personalized focus to healthcare.   Patients may experience longer visits, an emphasis on preventive care, […]

“Election Lock” Solved For Participants Who Wish To Enroll In Marketplace Coverage

Background Under Change of Status rules in effect prior to October 2014, a cafeteria plan may not allow an employee to revoke an election under the group health plan during a period of coverage solely to enroll in a Qualified Health Plan through a Marketplace or Exchange. Consequently, employees participating in benefits with non-calendar year […]

IRS Guidance on How Health FSA Carryover Affects Eligibility for HSA Contributions

The IRS released a memorandum on March 28, 2014 that confirms that employees who have carryover from a prior year in a general purpose health FSA cannot contribute to an HSA in the following year.  However, employees may contribute to an HSA if the FSA funds are moved to an HSA-compatible health FSA or if […]

COBRA for HRAs – A Plan for Determining COBRA Premiums

Under COBRA law, when a covered individual loses coverage under an employer’s group health plan because of a triggering event (such as termination of employment or divorce), they must be given an opportunity to elect to continue the same health coverage they had on the date of the triggering event. If the coverage consisted of an insured […]

The Latest Guidance on HRAs & FSAs Under Health Care Reform

On September 13, 2013, The Department of Treasury (IRS) and Department of Labor (DOL) released yet more guidance called The “Application of Market Reform and other Provisions of the Affordable Care Act to HRAs, Health FSAs, and Certain other Employer Healthcare Arrangements”.  IRS Notice 2013-54 (which has substantially the same text as contained in the DOL release) addressed  three […]

When Does an Employer Have to Provide a HIPAA Privacy Notice?

Sometimes our clients ask if NEO sends a HIPAA Privacy Notice to their employees who are enrolled in the Health FSA or Health Reimbursement Account (HRA) plan that we manage.  In the case of a self-funded plan like an FSA or HRA, the employer is the Covered Entity responsible for issuing the Privacy Notice. As a Business Associate of […]