by admin | Apr 17, 2025 | Blog
HIPAA special enrollment rights allow eligible employees to enroll in health plans outside the regular enrollment period due to specific life events. These rights also impact Health Reimbursement Arrangements (HRAs), Health Savings Accounts (HSAs), and Flexible Spending Accounts (FSAs).
When and Who Receives the Notice?
Notices must be provided to all eligible employees at or before the time they are first offered the opportunity to enroll. This includes employees who:
- Decline coverage due to other health insurance and later lose eligibility.
- Become eligible for state premium assistance under Medicaid or CHIP.
- Acquire a new spouse or dependent by marriage, birth, adoption, or placement for adoption.
What Should the Notice Include?
The notice must describe special midyear enrollment opportunities and inform participants about deadlines for enrollment requests—30 days for most events, 60 days for Medicaid or CHIP-related events.
Distribution Methods
Include the notice with plan enrollment materials and, if conditions are met, distribute it electronically.
Impact on HRAs, HSAs, and FSAs
Special enrollment rights can affect contributions and usage of HRAs, HSAs, and FSAs:
- HRAs: Adjust contributions or usage to align with new coverage.
- HSAs: Review HSA contributions and ensure compliance with IRS rules.
- FSAs: Update FSA elections to reflect changes in coverage or dependent status.
Consequences of Non-Compliance
Failing to provide the notice timely can lead to enrollment issues and potential penalties from the Department of Labor (DOL).
Providing HIPAA special enrollment notices is essential for compliance and helps employees make informed decisions about their health coverage and financial accounts. Understanding the impact on HRAs, HSAs, and FSAs ensures that employees can effectively manage their health-related financial accounts in conjunction with their health plan enrollment.
Source: Thomson Reuters
by admin | Apr 10, 2025 | Blog
If your company sponsors a self-insured health plan, you might be wondering whether you still need to pay Patient-Centered Outcomes Research Institute (PCORI) fees. These fees, which fund research on patient-centered outcomes, have been a requirement for several years. However, there have been changes to the legislation that you should be aware of. In this post, we’ll clarify the current requirements for PCORI fees and what you need to do to stay compliant.
What Are PCORI Fees?
PCORI fees are paid by health insurers and sponsors of self-insured health plans. The funds collected are used to support research that helps patients, clinicians, purchasers, and policymakers make informed health decisions.
Legislative Background
Initially, PCORI fees were required for plan and policy years ending before October 1, 2019. For calendar-year plans, this meant that the 2018 plan year was supposed to be the last year for which these fees applied. However, budget legislation passed in 2019 reinstated the PCORI provision, extending the fee requirements through plan years ending before October 1, 2029.
Current Requirements
As of now, if your self-insured health plan’s policy year ends on December 31, 2024, you are required to pay the PCORI fee. This fee is considered an excise tax under the Internal Revenue Code and must be reported on IRS Form 720. Although Form 720 is filed quarterly for other federal excise taxes, the PCORI fee reporting and payment are only required annually. The deadline for filing Form 720 for the 2024 plan year is July 31, 2025.
Record-Keeping
The instructions for Form 720 advise taxpayers to keep their tax returns, records, and supporting documentation for at least four years from the latest of the date the tax became due or the date the tax was paid. This is crucial for ensuring compliance and being prepared for any potential audits.
Conclusion
In summary, PCORI fees are still required for self-insured health plans through plan years ending before October 1, 2029. Make sure to file IRS Form 720 by July 31, 2025, for the 2024 plan year, and keep all related documentation for at least four years. Staying informed and compliant will help your company avoid any penalties and contribute to valuable health outcomes research.
Source: Thomson Reuters
by admin | Apr 4, 2025 | Blog
Health Savings Accounts (HSAs) are a valuable tool for managing healthcare expenses, especially for those enrolled in high-deductible health plans (HDHPs). However, understanding the contribution limits can be tricky, particularly for married couples with self-only HDHP coverage. In this post, we’ll clarify whether spouses with self-only HDHP coverage can share their HSA contribution limits and provide insights into maximizing their contributions.
HSA Contribution Limits
For 2025, the HSA contribution limits are as follows:
- Self-Only HDHP Coverage: $4,300
- Family HDHP Coverage: $8,550
Additionally, individuals aged 55 or older can make a “catch-up” contribution of up to $1,000 to their HSA.
Special Rule for Married Individuals
When at least one spouse has family HDHP coverage, a special rule allows the spouses to share the higher family contribution limit. Either spouse’s HSA can receive contributions up to the family maximum, but their combined contributions cannot exceed the family limit. It’s important to note that HSAs are individual accounts, and married couples cannot maintain a joint HSA.
Scenario: Both Spouses Have Self-Only Coverage
In the situation where both spouses have self-only HDHP coverage, the special rule for married individuals does not apply. Each spouse’s contributions will be subject to the self-only limit, including any catch-up contributions if they meet the age requirement. One spouse cannot increase the other spouse’s maximum HSA contributions by contributing less.
Maximizing Contributions
If both spouses with self-only coverage each maintain HSAs and contribute the maximum amount, their aggregate contributions will be slightly more than the family limit ($8,600 versus $8,550). However, they lose the flexibility to place a disproportionate amount of the contribution into one spouse’s HSA. To maximize their aggregate contribution, married couples should:
- Maintain two HSAs.
- Maximize contributions to each HSA.
Considerations for Choosing Coverage
When deciding whether to elect self-only HDHP coverage from their respective employers or family HDHP coverage from one employer, married couples should consider various factors, including:
- Premium costs
- Provider networks
- Deductible and other cost-sharing amounts
- Any spousal surcharges
Understanding HSA contribution limits and rules is crucial for married couples with self-only HDHP coverage. By maintaining individual HSAs and maximizing contributions, they can effectively manage their healthcare expenses. Always consider the broader implications of your HDHP coverage choices to ensure you make the best decision for your financial and healthcare needs.
Source: Thomson Reuters
by admin | Mar 20, 2025 | Blog
Navigating the requirements for Summary Plan Descriptions (SPDs) under ERISA health and welfare plans can be complex. Ensuring compliance is crucial for plan administrators, especially for COBRA qualified beneficiaries. This guide will help you understand who must receive SPDs and the specific considerations for COBRA compliance.
Who Must Receive SPDs?
Plan administrators must automatically furnish SPDs to all participants covered under ERISA health and welfare plans. This includes current employees, former employees who are or may become eligible for benefits, and their beneficiaries.
COBRA Qualified Beneficiaries
COBRA qualified beneficiaries are a key group that must receive SPDs. These individuals have the right to continue their health coverage under the plan after certain qualifying events, such as termination of employment or reduction in hours. Here are the specific considerations:
- Automatic Provision of SPDs: COBRA qualified beneficiaries must receive SPDs automatically.
- Single SPD for Same Address: Separate SPDs are generally not required for qualified beneficiaries living at the same address.
Other Categories of Individuals Who Must Receive SPDs
In addition to COBRA qualified beneficiaries, the following categories must also receive SPDs:
- Employees or Former Employees Covered Under the Plan: Current plan participants and former employees, such as retirees, who remain covered under the plan.
- Alternate Recipients Under QMCSOs: Typically furnished to the child’s custodial parent or guardian.
- Spouses or Dependents of Deceased Participants: Those who continue to receive benefits under the plan.
- Representatives or Guardians of Incapacitated Persons: Sent to the individual’s representative or guardian.
Triggering Events for Automatic SPDs
ERISA specifies the events that trigger the requirement to automatically furnish SPDs. Additionally, SPDs must be provided to plan participants and beneficiaries who request them.
Understanding who must receive SPDs and the specific requirements for COBRA qualified beneficiaries is essential for compliance with ERISA health and welfare plans. By following these guidelines, plan administrators can ensure they meet their obligations and provide necessary information to all eligible participants.
Source: Thomson Reuters
by admin | Mar 14, 2025 | Blog
As the FSA grace period draws to a close on March 15, it’s crucial to make the most of your remaining funds. Flexible Spending Accounts (FSAs) offer a fantastic way to save on healthcare expenses, but any unused money will be forfeited if not spent by the deadline. To help you avoid losing your hard-earned dollars, here are five essential items you can purchase with your leftover FSA money:
1. Prescription Eyewear
Why not treat yourself to a stylish new pair of prescription glasses or contact lenses? Not only will you see better, but you’ll also have a chic accessory. Check out the options at the FSA Store.
2. Over-the-Counter Medications
Stock up on everyday essentials like pain relievers, allergy meds, and cold remedies. These are FSA-eligible and super handy to have around. You can find a wide selection at the FSA Store.
3. First Aid Supplies
Be prepared for minor injuries and emergencies by updating your first aid kit. Grab some bandages, antiseptic wipes, and gauze. Check out the FSA Store for all your first aid needs.
4. Health and Wellness Products
Consider investing in health and wellness products like heating pads, hot/cold packs, or even a new humidifier. These items are FSA-eligible and can help you stay comfortable and healthy. Explore the options at the FSA Store.
5. Sunscreen and Skincare Products
Protect your skin by investing in high-quality sunscreen and skincare products. Many of these items are FSA-eligible, making them a smart choice for using up your remaining funds. Check out the FSA Store for some great options.
Don’t let your FSA money go to waste! By purchasing these essential items, you can maximize your savings and ensure you’re well-prepared for the year ahead. Remember to check with your FSA provider for a complete list of eligible expenses and make your purchases before the grace period ends. For a full list of eligible FSA items click here.
