cmonfils | May 9, 2012
| In November 2011, the IRS, DOL and HHS issued Part VII of their Frequently Asked Questions About Affordable Care Act Implementation (“FAQs”). In particular, the FAQs provide guidance on the Mental Health Parity and Addiction Equity Act (“MHPAEA”) requirement that the limits applicable to mental health and substance abuse benefits offered through a group health plan cannot be more restrictive than the financial, treatment, and non-quantitative limits of the plan’s medical and surgical benefits. |
Category: DOL, Health Care Legislation, HHS, IRS, Mental Health Parity, PPACA |
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cmonfils | May 3, 2012
By Ron E. Peck, Esq.
Self-funding a health benefit plan brings with it many risks and rewards. Before an employer can decide whether to self-fund, however, they must first understand what self-funding is. You may be surprised to learn that more than half of insured Americans are members of a self-funded health benefit plan. Yet, most self-funded plan members likely have no idea that they are self-funded, or if they are aware, they have no idea what that means. (more…)
Category: DOL, ERISA, Health Care Legislation, HHS, PPACA, Self-Funding, Stop Loss |
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cmonfils | May 1, 2012
www.myhealthguide.com
MyHealthGuide Source: Hilda L. Solis, Secretary of Labor, April 2012, DOL Full Report
Executive Summary
The Patient Protection and Affordable Care Act (the “Affordable Care Act”) (P. L. 111-148, as amended) requires the Secretary of Labor to provide Congress with an annual report containing general information on self-insured employee health benefit plans and financial information regarding employers that sponsor such plans. The report must use data from the Annual Return/Report of Employee Benefit Plan (the “Form 5500″) which many self-insured health plans are required to file annually with the Department of Labor (the “Department”). The first report was provided to Congress in March 2011. (more…)
Category: DOL, Form 5500, PPACA, Self-Funding |
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cmonfils | May 1, 2012
www.siia.org
The Self-Insurance Institute of America, Inc. (SIIA) today obtained an advance copy of a Request for Information (RFI) notice regarding stop-loss insurance to be officially issued by The Departments of Labor, Treasury and Health and Human Services on May 1. The Departments’ stated intent for the request for comments is to contribute to the Departments’ understanding of the current and emerging market for stop-loss products. (more…)
Category: DOL, HHS, Self-Funding, Stop Loss |
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cmonfils | April 25, 2012
In February, the Departments of Labor, Treasury, and Health and Human Services issued final regulations implementing the new summary of benefits and coverage requirement under the Patient Protection and Affordable Care Act. The agencies also released a separate document providing additional guidance on the SBC requirement, which includes a template for the summary, instructions, sample language, a guide for coverage example calculations and the uniform glossary.
http://ebn.benefitnews.com/news/ppaca-dol-hhs-sbc-group-health-coverage-2723290-1.html?mstr_chnnl=ebn_health_care_reform
Category: DOL, Health Care Legislation, HHS, PPACA, SBC |
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cmonfils | April 24, 2012
Recent written audit requests to health and welfare plans from the U.S. Department of Labor (DOL) have included inquiries related to various mandates under the Affordable Care Act (the ACA or the Act). This is a significant development in the ongoing implementation of the ACA’s various coverage and related mandates, in that it marks the first appearance of ACA-related topics in DOL auditing practices. While the recent U.S. Supreme Court oral arguments caused speculation as to the future of the ACA, unless and until the ACA is ruled unconstitutional by the Supreme Court, the Act is enforceable and will be enforced by the DOL. Thus, employer-provided group health plans must continue to comply and otherwise implement the ACA’s various coverage and related mandates. Likewise, plan sponsors must comply with any ACA-related DOL audit requests, and be prepared to produce documents to prove that their plan complies with the ACA’s various mandates.
Category: DOL, Health Care Legislation, PPACA, Supreme Court |
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cmonfils | April 24, 2012
It may seem paradoxical that the U.S. Department of Labor (DOL) should begin auditing health plans for compliance with the health reform law’s mandates, given that the U.S. Supreme Court could very well strike down the Affordable Care Act (ACA) for being unconstitutional in early summer. But it’s better that plans be ready to demonstrate compliance with the coverage mandates that are presently hanging in the balance.
Category: DOL, Health Care Legislation, PPACA |
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cmonfils | April 11, 2012
In a field assistance bulletin, the Department of Labor (DOL) addressed when the use of Employee Retirement Income Security Act of 1974 (ERISA) plan assets to pay for marketing and graduation ceremonies for training and apprenticeship programs may be permissible. To promote compliance with these standards, the DOL recommends that plans establish internal controls designed to prevent inappropriate, excessive or abusive expenditure of plan assets.
Category: DOL, ERISA |
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cmonfils | April 5, 2012
The Department of Labor released a set of “Frequently Asked Questions” to clarify some of the basic aspects of preparing and providing the new Summary of Benefits and Coverage. Notable in the release is the announcement of a “good faith” compliance standard for the first year the SBC requirement is applicable.
Category: DOL, SBC |
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cmonfils | April 5, 2012
Washington, D.C. — ERIC, as part of a coalition of 14 other business trade associations, on March 27 urged the Department of Labor to permit broader use of electronic communications to deliver the disclosures to retirement plan participants required by new DOL regulations.
Category: DOL, ERIC, ERISA |
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cmonfils | April 2, 2012
www.myhealthguide.com
MyHealthGuide Source: Frederick D. Hunt, Active Past President, Society of Professional Benefit Administrators (SPBA), 3/20/2012, www.SPBATPA.org
An idea floated recently is for TPAs “and similar” to give away free contraceptive services. The vague “and similar” can include stop-loss providers, attorneys, brokers, consultants, PPOs, PBMs, etc. As described below, this is a desperate political grasping for straws concept. However it is important for the government and other “idea” people to realize that service providers are merely service providers, period…..not responsible deep pockets or “insurers”. (more…)
Category: DOL, Health Care Legislation, Health Insurance, HHS, Third Party Administrators |
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cmonfils | March 23, 2012
It had to happen sooner or later. Republicans are taking the issue of the ACA’s mandatory contraceptive coverage provisions to court. On February 15, the Labor Department, the HHS, and the IRS issued regulations reaffirming that certain religious employers are allowed an exemption for covering FDA-approved contraceptives as a part of a health plan. However, beginning August 1, 2012, most new and renewed health plans will be required to provide contraceptive services for women without cost sharing.
Category: DOL, Florida, Health Care Legislation, Health Insurance, HHS, Michigan, Nebraska, Ohio, Oklahoma, PPACA, South Carolina, Texas |
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cmonfils | March 19, 2012
On the same day that they released final regulations on the Summary of Benefits and Coverage (see our recent Client Alert on SBCs), the Departments of Labor, Health and Human Services, and Treasury (the “Departments”) also issued a joint set of frequently asked questions (FAQs) addressing various topics under the Affordable Care Act (“ACA”), including automatic enrollment, employer shared responsibility, and waiting periods. IRS Notice 2012-17 (which was issued in substantially identical form by the other two Departments) provides guidance, as well as suggestions regarding various approaches that the Departments are considering proposing in future regulations.
Category: DOL, Health Care Legislation, HHS, PPACA, SBC |
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cmonfils | March 14, 2012
It’s been two years since passage of a controversial federal law guaranteed break time and private space for nursing mothers to express milk at work. Women’s rights and business groups say many women who could benefit from the new right may not know about it.
Category: DOL, PPACA |
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cmonfils | March 4, 2012
Employers Guide to Self-Insuring Health Benefits February 2012 | Vol. 19, No. 5
What happens when an employer plan’s third-party administrator (TPA) absconds with funds and leaves the plan thrashing around trying to find ways to stay solvent?
In this case, two liability insurers denied an employer an insurance award for a loss that came about because its self-funded plan’s TPA misappropriated funds. The employer went to court to compel them to cover more than half a million dollars in losses. The outcome is still uncertain. (more…)
Category: DOL, ERISA, Fiduciary Liability, Ohio, Self-Funding, Third Party Administrators |
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