October 4, 2021 Today, the Departments of Labor, Health and Human Services (HHS), and the Treasury released Frequently Asked Questions (FAQs) regarding implementation of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Affordable Care Act. These FAQs provide guidance of how receiving COVID-19 vaccinations for eligibility HIPAA nondiscrimination, premium discounts under HIPAA wellness program purposes and for determining affordability of coverage with respect to the employer mandate. The important FAQs are provided below: Q3: May a group health plan (or health insurance issuer… Read More
August 21, 2021 On Saturday afternoon, the Departments of Labor, Health and Human Services (HHS), and the Treasury (collectively, the Departments) issued twelve (12) Frequently Asked Questions (FAQs) regarding implementation of certain provisions of the Affordable Care Act (ACA) and certain provisions of title I (the No Surprises Act) and title II (Transparency) of Division BB of the Consolidated Appropriations Act, 2021 (the CAA). These 12 Q&As address: Transparency in Coverage Machine-Readable Files Price Comparison Tools Transparency in Plan or Insurance Identification Cards Good Faith Estimate Advanced Explanation of Benefits Prohibition on Gag Clauses on Price and Quality Data Protecting… Read More
Late Tuesday afternoon, the IRS released the eagerly anticipated guidance regarding the COBRA premium assistance provisions of the American Rescue Plan Act of 2021. This Notice 2021-31 contains 86 questions and answers. Among the issues discussed, this Notice addresses who is eligible for this COBRA premium assistance and what constitutes a reduction in hours of employment or an involuntary termination of employment that makes an individual eligible for the COBRA premium assistance. The Notice addresses what coverage is eligible for the premium assistance, the period of time that the premium assistance is available, and the extended election period for COBRA coverage…. Read More
HSA limits for 2022 were announced today, May 10, 2021. The IRS released the limits for HSAs via Revenue Procedure 2021-25 as follows: Self-Only Enrollment in a High Deductible Health Plan (HDHP) 2022 HSA Limits: Maximum annual contribution: $3,650 ($3,600 in 2021) Minimum deductible for the HDHP to be HSA-qualified: $1,400 (no change from 2021) Maximum HDHP out-of-pocket limit: $7,050 ($7,000 in 2021) Family Enrollment in a High Deductible Health Plan 2022 HSA Limits: Maximum annual contribution: $7,300 ($7,200 in 2021) Minimum deductible for the HDHP to be HSA-qualified: $2,800 (no change from 2021) Maximum HDHP out-of-pocket: $14,100 ($14,000 in 2021) A… Read More
The Internal Revenue Service released Notice 2021-26 which clarifies the taxation of dependent care assistance benefits that were available in 2021 and 2022 due to either the carryover of unused benefits or the extended claims period. Under the various COVID-19 related relief provisions, dependent care assistance benefits that would have been available in 2020 or 2021 could be used in a later year. This Notice provides that these benefits will be excluded from an employee’s gross income when they are used in 2021 or 2022. In addition, these amounts will not be taken into account for determining the dollar limit on dependent care assistance benefits… Read More
