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What Group Health Plan Documents Must Be Provided to a Participant Upon Request?
QUESTION: Our company has just received a letter from a participant in our health plan, asking for copies of numerous documents relating to the plan. What are our responsibilities? ANSWER: ERISA § 104(b)(4) requires a plan administrator to furnish...
Are PCOR Fees Plan Expenses?
QUESTION: Our company sponsors a calendar-year self-insured major medical plan subject to ERISA. Are we permitted to treat Patient-Centered Outcomes Research (PCOR) fees as plan expenses? ANSWER: The DOL has indicated that PCOR fees generally are not permissible...
Must Our Plan Offer COBRA Coverage to Spouses and Dependents Whose Coverage Was Dropped at Open Enrollment?
QUESTION: When employees drop coverage for dependents or spouses under our company’s group health plan during open enrollment, our practice has been to provide the dropped individuals with COBRA election materials. However, our new COBRA TPA says this is not...
May Terminating Employees Elect COBRA Coverage for Domestic Partners?
QUESTION: Our company will soon begin offering coverage under our group health plan to employees’ domestic partners. What rights do domestic partners have under COBRA? May terminating employees elect to continue coverage for their domestic partners?...
IRS Announces 2024 Standard Mileage Rates and Maximum Vehicle Values
The IRS has announced the optional 2024 standard mileage rates for business, medical, and other uses of an automobile, and the 2024 vehicle values that limit the application of certain rules for valuing an automobile’s use. For 2024, the business standard mileage rate...
Are Any Group Health Plans Exempt From the Federal Mental Health Parity?
QUESTION: We are wondering if our company’s medical plan might qualify for an exemption from the federal mental health parity requirements. What exemptions are available? ANSWER: The federal mental health parity requirements apply to most employer-sponsored...
Is the HSA Contribution Limit an Annual or Monthly Limit?
QUESTION: How does the general contribution limit for HSAs work? It is often stated as an annual limit, but isn’t it really monthly? Our company is thinking about changing to HDHP coverage that would allow our employees to make HSA contributions. If we decide to...
Agency RFI Focuses on No-Cost Coverage of OTC Preventive Products Without a Prescription
A DOL, HHS, and IRS request for information (RFI) is seeking input about how the preventive health services mandate applies to over-the-counter (OTC) preventive items and services, including the potential benefits and costs of requiring plans and insurers to cover...
2024 FSA Limit Increases: What To Know
The IRS announced 2024 contribution limits for all Flexible Spending Account (FSA) plans. Below is an overview of the limit increases across all the types of FSAs except for Dependent Care FSAs, which remain the same at $5,000 per year. Health Flexible Spending...
When Is a Qualified Beneficiary Considered “Entitled to Medicare” for Purposes of Terminating COBRA Coverage Early?
QUESTION: We understand that our group health plan can terminate COBRA coverage early if a qualified beneficiary becomes entitled to Medicare after electing COBRA. What does it mean to be “entitled” to Medicare? ANSWER: When qualified beneficiaries...
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