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If a pharmacy benefits manager promises a group health plan that there will be no administrative fee for drugs, it actually could be a red flag and not a cause for celebration. It could mean the PBM is “gaming the spread” or not passing rebates through to the plan. Plans can prevent this kind of […]
IRS officials described when employers themselves have to fill out full information on all health plan enrollees along with months enrolled, and when employers can hand that over to another entity, such as an insurer. Most employers offer minimum essential coverage to employees; the purpose of Section 6055 reporting is to demonstrate that they are […]
The U.S. Supreme Court ruling that “closely held” for-profit companies can — on religious grounds — opt out of a federal requirement to provide certain contraception coverage is rife with implications for self-insured and other employer-sponsored health plans. The ruling is unlikely to lead to a wide variety of religiously inspired opt-outs, benefits attorneys held, […]
Employers have cited complying with the Affordable Care Act as their number one concern in surveys, and that wouldn’t be the case if there weren’t taxes and money penalties backing it up. This is true even though the government postponed until 2015 penalties for failure to comply with the ACA’s play-or-pay mandates, temporarily reducing the […]
Government requirements for certifying compliance with HIPAA’s transaction standards would impose a significant, unwarranted burden on self-funded group health plans that do not perform these transactions directly, employer groups warned in written comments to the U.S. Department of Health and Human Services. The proposed rules would lay “significant costs” on self-insured plans that hire vendors […]
How a company complies with health care reform should be determined by what kind of employer it is, how exclusive its workforce is, and how important its benefit package is seen as an aid to recruitment and retention. Only after that analysis should an employer look at whether gains can be made by, say, reducing […]
On Feb. 26, SIIA’s CEO and president Mike Ferguson testified before a House panel to make it clear that skirting the ACA is not the reason companies and institutions self-insure, contrary to what pro-reform elements in the federal government may believe. The decision whether to self-fund is based on risk tolerance, understanding of legal liability, […]
The 7th Circuit in a 2-1 ruling refused to grant a preliminary injunction to Notre Dame University, which would have freed the university from participating in reform’s requirement to provide contraceptives at no cost to all women. In so doing the court criticized the university’s argument that signing an EBSA Form 700 — expressing objections to the contraceptive […]
Generally, waiting periods to enroll in health coverage cannot exceed 90 days, and eligibility conditions based solely on the lapse of a time period are permissible for no more than 90 days, under new final rules issued by the U.S. Departments of Labor Health and Human Services and the Treasury. In addition, the employer has […]
A series of agency Q&As resolves a few questions relating to complying with federal health care reform, such as correctly counting participants’ out-of-pocket expenditures; wellness program reward administration; and the status of “carved-out” benefits. In latest set of Frequently Asked Questions, the U.S. Departments of Labor, Health and Human Services and the Treasury provide some […]