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IRS DECREASES 2024 ACA AFFORDABILITY TO 8.39% The IRS has announced a reduction in the Affordable Care Act (ACA) affordability percentage for plan years starting in 2024, lowering it from 9.12% in 2023 to 8.39%. This affordability percentage determines the maximum portion of an employee’s household income that can be spent on self-only coverage while still complying…
PROPOSED CHANGES TO SHORT-TERM, LIMITED-DURATION INSURANCE On July 7, 2023, the U.S. Department of Health and Human Services (HHS), the Department of Labor (DOL), and the Department of the Treasury proposed changes to modify the definition of short-term, limited-duration insurance (STLDI) and the conditions for fixed indemnity insurance to be considered an excepted benefit. The…
PCORI FEE DUE DATE APPROACHES Employers offering self-funded medical plans, including health reimbursement arrangements (HRAs) must report and pay fees to the Patient-Centered Outcomes Research Institute (PCORI) by July 31. If the plan was fully insured, employers can rely on their insurance carriers to handle the fee payment. The current annual fees are: For plan years…
CLAIMS SUBSTANTIATION FOR PAYMENT OR REIMBURSEMENT OF MEDICAL AND DEPENDENT CARE EXPENSES A memorandum released by the IRS Chief Counsel responds to a request for assistance regarding the reimbursement of medical and dependent care expenses. Addressed is whether reimbursements of medical expenses from a health flexible spending arrangement (FSA) provided in a cafeteria plan should…
2024 BENEFIT PARAMETERS FOR MEDICARE PART D CREDITABLE COVERAGE DISCLOSURES ANNOUNCED The Centers for Medicare and Medicaid Services (CMS) released a Fact Sheet announcing the 2024 benefit parameters for Medicare Part D. These factors are used to determine the actuarial value of defined standard Medicare Part D coverage under CMS guidelines. Each year, Medicare Part D requires…
When the COVID-19 public health emergency and national emergency were declared in 2020, no one anticipated they would still be in place in 2023. On January 30, 2023, the President announced the intent to end the emergencies on May 11, 2023. The impact of the emergencies on employer-sponsored benefits affected certain coverages, reimbursements, and timelines.…
IRS RELEASES 2024 EMPLOYER SHARED RESPONSIBILITY PROVISION PENALTIES The dollar amount used to calculate the employer shared responsibility provision penalties (ESRP) has been provided for 2024. As background, the penalties can be assessed under Code § 4980H(a) if an applicable large employer (ALE) fails to offer minimum essential coverage to the required number of full-time…
By way of background, the Affordable Care Act (ACA) created the Patient-Centered Outcomes Research Institute (PCORI) to study clinical effectiveness and health outcomes. To finance the Institute’s work, a small annual fee—commonly called the PCORI fee—is charged on group health plans. Grandfathered health plans are not exempt. Most employers do not have to take any…
We recently informed you that the machine-readable file (MRF) requirement under the Transparency in Coverage (TiC) rules goes into effect July 1, 2022. This part of the rule requires that insurers and self-funded group health plans must begin to publicly post machine-readable files with detailed information on the costs of covered services and prescription drugs.…
The Departments of Health and Human Services, Labor, and Treasury (the Departments) released Transparency in Coverage (TiC) rules in late 2020 that will require fully insured and self-funded plan sponsors of non-grandfathered group health plans to make important disclosures about in-network and out-of-network rates beginning July 1, 2022. To be ready to meet that deadline,…
