December 28 , 2010

Nondiscrimination Rules Deferred for Insured Group Health Plans

On December 22, 2010, the IRS released Notice 2011-1, which defers application of certain nondiscrimination requirements applicable to insured group health plans under the Affordable Care Act.  This comes as great relief to plan sponsors, who would have been subject to substantial penalties with no regulatory guidance to inform them of their obligations. 

For more details on this deferral...

Download the full article (PDF) >>

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November 19 , 2010

Change Made to Grandfathering Regulations

On November 15, 2010, the Departments of Labor, Health and Human Services, and Treasury issued an amendment to the interim final regulations relating to the status of grandfathered health plans under the Patient Protection and Affordable Care Act.  This allows for group health plans to switch insurance companies without forfeiting grandfathered status, so long as the plan is not otherwise changed in a manner that violates one of the other rules for maintaining grandfathered status. 

For more details on this recent change to the grandfathering regulations...

Download the full update (PDF) >>

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October 14 , 2010

Reporting of New Health Care Costs Deferred

The IRS has issued a draft Form W-2 for 2011, which employers use to report wages and employee tax withholding.  The IRS also announced that it will defer the new requirement for employers to report the cost of coverage under an employer-sponsored group health plan, making that reporting by employers optional in 2011. 

For more details on this deferral...

Download the full update (PDF) >>

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October 8 , 2010

Changes in OTC Drug Coverage 2011

Over-the-counter medicines or drugs purchased without a prescription on or after January 1,2011 (other than insulin) may no longer be paid for or reimbursed under health flexible spending arrangements ("FSAs"), health reimbursement arrangements ("HRAs"), health savings accounts ("HSAs"), or Archer Medical Savings Accounts ("MSAs").  The IRS recently released documentaiton which provides further guidance on these changes made by the Affordable Care Act. 

For further details on these changes to OTC drug coverage...

Download the full update (PDF) >>

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October 8 , 2010

New Nondiscrimination Rules

In recent months, Dominion Benefits has kept our clients informed on Health Care Reform related developments and emerging employer responsibilities. We realize this information can sometimes be overwhelming but we'd rather risk over-communicating.  Today, we want to send a brief reminder on one key aspect of Health Ccare Reform that can significantly impact your medical program - nondiscrimination rules now apply to any "non-grandfathered" fully insured medical plan.

For details on these new rules...

Download the full update (PDF) >>

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October 7 , 2010

Medicare Part D Creditable Coverage

Are you ready for November 15?

Medicare Part D imposes two annual notice requirements on all employers that offer group health plan coverage with a prescription drug benefit:

1. Employers are required to send participants either a Notice of Creditable Coverage or a Notice of Non-Creditable Coverage, whichever is applicable, by November 15, 2010.
2. Employers must also notify the Centers for Medicare and Medicaid Services about their plan's creditable coverage status no later than the 60th day after the start of each plan year.

For further information on these important requirements...

Download the full update (PDF) >>

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October 6 , 2010

Year-End Roundup

The recent enactment of the Patient Protection and Affordable Care Act and the Health Care and Reconciliation Act of 2010 (collectively, "The Affordable Care Act"), includes changes that require implementation before year-end, and in some cases, these changes will require notices during upcoming open enrollment.  The impact of many of these changes will depend on whether the relevant group health plan is grandfathered.

For details on these specific requirements...

Download the full update (PDF) >>

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July 8 , 2010

Regulations Released for Pre-existing Condition Exclusions, Limits, Rescissions, etc.

On June 23, 2010, the Departments of Labor, Health and Human Services and Treasury released final interim regulations relating to preexisting condition exclusions, lifetime and annual limits, rescissions, and other patient protections under the Affordable Care Act. The Regulations were published in the June 28, 2010 Federal Register.

For more details on these final regulations...

Download the full update (PDF) >>

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June 25 , 2010

Grandfathered Health Plan Provisions

On June 14, 2010, the Departments of Labor, Health and Human Services, and Treasury released final interim regulations relating to the status of grandfathered health plans under the Affordable Care Act (the “Act”). These regulations, published in the June 17, 2010 Federal Register, explain the rules for determining whether a group health plan or health insurance coverage qualifies as a grandfathered health plan, how that status is maintained, and how a grandfathered health plan may lose its grandfathered status.   In addition, the preamble to the regulations provides helpful and important guidance for plans that are not subject to the Act’s mandates, such as those that cover fewer than two participants who are current employees and those that provide excepted benefits.

Download the full update (PDF) >>

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April 19 , 2010

Congress Extends COBRA Subsidy Eligibility Period

Last week, Congress approved the Continuing Extension Act of 2010 (CEA), which extends the eligibility period for the ARRA COBRA subsidy for an additional two months (to May 31, 2010).  Accordingly, individuals who experience an involuntary termination of employment during April and May now may be eligible for the subsidy.  The CEA does not change the amount or duration of the subsidy. 

>> Download the full update (PDF)

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March 19 , 2010

U.S. Department of Labor Issues Updated COBRA Subsidy Notices

As we advised in our March 3, 2010 E-Bulletin, the Temporary Extension Act of 2010 (TEA) is now in place. This extension includes new notification requirements with regard to the federal government’s COBRA subsidy. Earlier this week, the DOL posted on itswebsite several model notices that may be used for compliance with these requirements, as well as additional guidance regarding the changes made by TEA. Specifically, the DOL has created:

• An updated General COBRA Election Notice;
• A notice of the new COBRA election period available to individuals who lost coverage due to reduced hours of employment at any time from September 1, 2008 through March 31, 2010 and subsequently experience a termination of employment between March 2 and March 31, 2010, and either did not elect COBRA at the time of the reduced hours or elected COBRA and then discontinued it;
• A supplemental information notice for individuals who have COBRA after March 1, 2010 and were not notified of the availability of the premium subsidy and also for individuals who have COBRA coverage based on an earlier reduction in hours of employment which is followed by a termination of employment between March 2 and March 31, 2010;
• A notice of the extended election period available to individuals whose termination of employment occurred on or after March 1, were provided with notice that did not inform them of their rights to the COBRA subsidy, and either did not elect COBRA or elected and discontinued COBRA;
• An updated Alternative Notice (for plans that provide continuation coverage pursuant to state law).
• For more detailed information and to view sample notices, you may visit the DOL’S COBRA page.

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March 10 , 2010

COBRA Subsidy Period Extended to 15 Months

We are pleased to report to you that the Virginia General Assembly has approved House Bill 554, and the Governor has signed into law legislation that extends the "mini-COBRA" subsidy beyond nine months in our state. This change allows any future time limit amendment that ARRA provides to be incorporated into Virginia law automatically.

Currently, ARRA provides for a subsidy to reduce COBRA and state continuation premiums for up to 15 months for individuals who were (or are) involuntarily terminated between September 1, 2008, through February 28, 2010, and who meet other eligibility requirements. This Virginia Enhanced Continuation subsidy period applies to groups with fewer tan 20 employees.

The insurance carrier is responsible for providing the 65% subsidy of the state continuation premium and they will seek reimbursement from the U.S. Department of Treasury. The member will be responsible for the remaining 35% of the premium.

Your carrier requires an application to enroll a person in the Virginia Enhanced Continuation subsidy. However, members already enrolled for the nine-month subsidy will automatically be extended to the 15-month subsidy.

If you have any questions regarding these changes, please call your Dominion Benefits Consultant or Client Manager.

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January 15 , 2010

Update on Model COBRA Notices

As a result of the recently passed COBRA Subsidy Extension Law, the DOL has released new Model COBRA Notices. As your partner, we are providing you with the latest information on the COBRA notification requirements. We will continue to keep you informed as we learn more.

Access the Model Notices >>

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