Inflation Reduction Act indirectly impacts employer-sponsored group health plans

Inflation Reduction Act indirectly impacts employer-sponsored group health plans

Congress has passed, and the President has signed, the Inflation Reduction Act of 2022. While the legislation largely focuses on climate change mitigation and deficit reduction, several provisions are of interest to group health plan sponsors and their advisors. Here they are as followed:

Enhanced Premium Tax Credit: The favorable premium tax credit rules adopted in the American Rescue Plan Act (ARPA) will now remain in effect through 2025. As background, the Affordable Care Act (ACA) created a refundable premium tax credit, which is available on a sliding-scale basis for individuals and families who are enrolled in an Exchange health plan and who are not eligible for other qualifying coverage or affordable employer-sponsored health insurance plans providing minimum value.

The ACA limits the credit to taxpayers with household income between 100% and 400% of the federal poverty line who purchase insurance through an Exchange health plan. ARPA eliminated the upper income limit for eligibility and increased the amount of the premium tax credit by decreasing, in all income bands, the percentage of household income that individuals must contribute for Exchange coverage. The adjusted percentage ranges from zero to 8.5%.

Medicare Prescription Drug Cost Reductions: Several cost reduction measures will benefit enrollees in Medicare Part D prescription drug coverage. Beginning in 2023, cost-sharing for insulin will be capped at $35 per month. Annual Part D out-of-pocket prescription drug costs will be capped at $2,000 starting in 2025. For the first time, the United States Department of Health and Human Services (HHS) will be authorized and required to negotiate certain Medicare drug prices with manufacturers beginning in 2026. In addition, starting in 2023, manufacturers must pay Medicare a rebate if average prices of certain drugs increase faster than inflation.

Note: Because the legislation does not include comparable prescription drug cost reductions for private plans, there is some concern that reduced costs for Medicare enrollees will result in increased costs for employer plans and participants as price increases are shifted to private plans to make up for lost revenue.

Insulin-Related HDHP Safe Harbor: The legislation amends to provide that plans will not lose their HDHP status by reason of failing to have a deductible for certain insulin products. This provision is effective for plan years beginning after December 31, 2022.

Note: The provision codifies and expands IRS guidance that allows HDHPs to provide insulin on a no-deductible or low-deductible basis under specified circumstances without adversely affecting HSA eligibility.

Source: Thomson Reuters

Inflation Reduction Act indirectly impacts employer-sponsored group health plans

When are carryover funds available for a new FSA member?

For new FSA members, there are two carryover fund options to take note of: Healthcare to Healthcare and Healthcare to Limited Purpose. Here they are followed:

Healthcare FSA to Healthcare FSA carryover

As of December 31, any funds up to $570 remaining in a Healthcare FSA will immediately carryover on the first day of the new plan year. This means that the carryover amount is simultaneously available to pay previous plan year expenses and current plan year expenses during the previous plan year run-out period.

Healthcare FSA to Limited Purpose FSA carryover

Remaining carryover funds in a Healthcare FSA as of December 31 can only be used for previous plan year dates of service until the end of the plan run-out period. Any dental or vision expenses incurred during the new plan year can be reimbursed either immediately from the new Limited Purpose FSA, or at the end of the run-out period when any remaining funds from the previous Healthcare FSA are carried over to the Limited Purpose FSA.

Inflation Reduction Act indirectly impacts employer-sponsored group health plans

8 ways NueSynergy’s mobile app is convenient and intuitive

NueSynergy is proud to provide a free mobile app that allows access to all benefit account holder’s information anywhere at any time. Our app’s goal is to make the user experience easy while providing innovative features for a participant to make important health care decisions. Here are eight ways NueSynergy’s mobile app can be of service to you.   

  • Helps with filing a claim and submitting documentation
  • View plan communications
  • Tracks up-to-date balance transactions, claims status, plan details and contributions
  • Provides prescription storing and cost savings opportunities
  • Offers transparency tools to evaluate providers and shop for procedures
  • Uses a geotracking feature to find nearby providers
  • Secure account communications for iPhone and Android devices
  • Allows you to enter and submit claim information by taking a photo of receipt and upload or attach receipt to a card transaction
Inflation Reduction Act indirectly impacts employer-sponsored group health plans

Dependent Care FSA: 5 Important Facts

A Dependent Care FSA, or DCA, is a flexible spending account that allows employees to contribute to a portion of their paycheck, pre-tax, to pay for qualified dependent care expenses. Here is a list of five facts regarding this account.

Fact #1: Any participant of this account can enjoy a 30% average tax savings on the total amount they contribute to a DCA.

Fact #2: Contributing money to this account starts by first making an annual election during open enrollment. From there, your employer will deduct the election amount from your paycheck before taxes are assessed in equal amounts throughout the year.

Fact #3: You can contribute up to the IRS limit of $5,000 annually on income tax returns if filing single or married jointly. If married and contributing to an account separately, you can contribute up to $2,500 each, or $5,000 total.

Fact #4: Eligible expenses for a DCA must be for the purpose of allowing you to work or look for work. Services may be provided at a child or adult care center, nursery, preschool, after-school, summer day camp, or a nanny in your home.

Fact #5: There are two methods to use funds in a DCA. One option is paying directly from your account through a benefits debit card (only if your care provider accepts credit cards). The second option is paying out-of-pocket and then file a reimbursement claim with your expense documentation.

Inflation Reduction Act indirectly impacts employer-sponsored group health plans

IRS extends SECURE Act and CARES Act amendment deadlines

The IRS has extended the deadlines for adopting retirement plan amendments to reflect certain provisions of the SECURE Act and the CARES Act. As background, under the SECURE Act, the plan amendment deadline for most plans is the last day of the first plan year beginning on or after January 1, 2022 (2024 for governmental and applicable collectively bargained plans). Similarly, the plan amendment deadline under the CARES Act is the end of the first plan year beginning on or after January 1, 2022.

For most plans, the notice extends the deadline to adopt applicable amendments until December 31, 2025. Later deadlines apply for governmental plans, but not collectively bargained plans. The notice revises previous guidance for certain required and discretionary SECURE Act amendments and for SECURE Act changes affecting safe harbor 401(k) plans. The extended deadlines also apply to amendments by defined contribution plans (including 401(k) plans) reflecting the waiver of required minimum distributions for 2020 under the CARES Act. Timely adopted amendments will not cause a plan to fail to satisfy the anti-cutback rules or ERISA so long as, in the interim, the plan operates as if a retroactive amendment were already in effect.

EBIA Comment: This notice does not extend the deadline for adopting retroactive amendments reflecting the CARES Act’s optional coronavirus-related distribution and loan relief—that deadline remains the last day of the first plan year beginning in 2022 (2024 for governmental plans). Keep in mind that, unlike the original deadline, which was determined with reference to the plan year, the extended deadline for most plans is a specific date, so non-calendar year plans receive less time than the general three-year extension. (Governmental plan deadlines are generally based on legislative sessions.) 

Source: Thomson Reuters

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