If certain conditions are satisfied, an applicable large employer may use one or more of the three affordability safe harbors to determine if it’s offering affordable coverage under the ACA. There are substantial limitations and risks associated with each safe harbor.
The federal poverty level safe harbor requires just one ...
Under recent IRS guidance, there will be minimal changes to the annual contribution limits to Health Savings Accounts (HSAs) that will be tax-deductible for 2017. Actually, there will only be one change from 2016. Under Rev. Proc. 2016-28, an individual may contribute $3,400 to an HSA under a high deductible health plan for 2017 ...
In 2013, the Department of Health & Human Services (“HHS”) announced a transitional policy that allowed insurers to renew non-grandfathered health insurance plans in the individual and small markets that did not comply with certain ACA mandates. This transitional relief is only available for individual and small market ...
It’s no secret that multiemployer pension plans, like most defined benefit plans, are underfunded. Unfunded pension liability, also referred to as employer withdrawal liability, creates substantial risks for more than the employers obligated to make contributions to these multiemployer pension plans. Multiemployer ...
Today, the DOL released the much anticipated fiduciary rule. The final regulations create a new playing field for certain investment professionals, which were previously not governed by ERISA’s fiduciary standards and rules governing prohibited transactions.
Citing a need to create better safeguards and protect ...
David M. Pixley
Under the ACA, non-grandfathered group health plans must limit enrollees’ out-of-pocket costs for essential health benefits. Under the final HHS Notice of Benefit and Payment Parameters for 2017, the HHS bumped up the out-of-pocket maximums. HHS based its calculations on two factors, the cost sharing limit for 2014, which ...
Last October in a post called HIPAA Enforcement is About to get Serious, I explained that HHS was receiving significant pressure to increase its enforcement activities and was about to commence its “Phase 2” audit program. After a slight delay in the launch date, yesterday HHS announced that the phase 2 audits are now getting off ...
There are a lot of reasons to have updated addresses for all your employees, COBRA is definitely one of them. Based on recent case law, it’s more important than ever for employers to have a change-of-address process that keeps the person responsible for providing COBRA election notices in the loop.
Qualified beneficiaries (e.g ...
Another unencrypted laptop is stolen; another health care provider is hit by HHS with significant penalties. This time, HHS has announced that Feinstein Institute for Medical Research (“Feinstein”) has agreed to pay $3.9 million to settle its HIPAA violations. As with the recent HHS settlement involving North ...
Nothing good can happen if you share PHI with a business associate without having a business associate agreement in place. North Memorial Health Care of Minnesota (“North Memorial”) learned that lesson this week when HHS announced that it had reached a $1.55 million settlement with the hospital. The HHS investigation ...