In April 2019, the Department of Health and Human Services (HHS) issued final regulations that were set to become effective January 1, 2020. HHS had expressed concern that the availability of a coupon may cause physicians and patients to choose an expensive brand name drug when a less expensive and equally effective generic or other alternative ...
Beginning in 2017, the IRS began accepting determination letter applications from an individually designed plan only for initial plan qualification and for qualification upon plan termination. Prior to 2017, these plans could submit an application once every five years to request the IRS’ blessing that its provisions were satisfactory ...
In 2013, the IRS established a program for issuing opinion letters for 403(b) pre-approved plans and began accepting applications for opinion letters. This program allows eligible employers that amend or restate their plans to retroactively correct defects in form of written 403(b) plans going back to the first day of the remedial amendment ...
As employers head into open enrollment season for health insurance there are numerous legal notices that must be provided to eligible employees. One of those annual notices was recently revised and a new model notice was provided by the Department of Labor’s Employee Benefit Security Administration.
The model Medicaid/CHIP notice was revised ...
Large employers must not only offer coverage to avoid the shared responsibility employer mandate penalties, but the cost of coverage must also be affordable. If you are a large employer required to provide health plan coverage to avoid the shared responsibility penalties, it is prudent to reevaluate your contribution structure each year ...
Most employers that sponsor a group health plan subject to COBRA are aware that employees and any covered dependents must be offered COBRA continuation coverage when an employee or dependent loses coverage under the plan. What many employers do not expect is that employees terminated for gross misconduct do not have a right to COBRA coverage ...
The IRS has responded to President Trump’s Executive Order (discussed in our prior blog post) with a Notice issued this week. The June Executive Order directed the IRS to issue guidance to expand the care high deductible health plans (“HDHP”) can cover before participants reach their deductible, while still allowing the participant to ...
If you sponsor a self-insured group health plan, make sure you’ve set your calendar alerts for the annual PCORI fee (Patient-Centered Outcomes Research Institute fee) for the 2018 plan year. As a reminder, the PCORI fee was put into place by the ACA to help fund the Patient Outcomes Research Institute and is based on the average number of covered ...
On June 24, 2019, President Trump issued the “Executive Order on Improving Price and Quality Transparency in American Healthcare to Put Patients First.” The Order affects the healthcare system at large, but this post focuses on the impacts the Order has on health plans, including the future changes a plan sponsor may have to make to their ...
By Lyndsey Barnett and Laura Caty
Marijuana is a Schedule 1 drug. Period.
Until the Drug Enforcement Agency (DEA) removes marijuana from the classification of a Schedule I drug and unless marijuana is legalized under federal law, group health plans do not have the option of covering medical marijuana. According to the DEA, Schedule I drugs have a ...