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Have you ever had to figure out if an employee has gained or lost eligibility for coverage under your employer group medical plan? Or tried to determine what happens to an employee’s coverage if they go on a leave of absence? Finding the answer to what would appear to be a straightforward question can end up feeling like you’ve been following clues in a treasure hunt, without ever finding the prize! And while it has always been difficult, some insurance carriers and third-party administrators (TPAs), in the name of flexibility and administrative ease, appear to be making the clues more cryptic, making it even more difficult to find that elusive answer, by stripping out what little eligibility language used to appear in the summary plan description (SPD) or certificate of coverage (CoC).
One of the compliance obligations that comes with offering employee benefits is the requirement to offer certain participants in certain plans the opportunity to continue coverage for some period of time in certain circumstances when coverage would otherwise have been lost. But which employers have to offer continuation? On which plans? When? To whom? For how long? The answers to these questions depend on several factors.
Have you had your cafeteria plan tested for nondiscrimination issues this year? Or, better yet, have you ever had your cafeteria plan tested for nondiscrimination issues? Take a deep breath. We’re here to help with a high-level overview of this requirement. Nondiscrimination testing must be done, but by making some plan design changes, an employer can definitely promote a passing grade.
One of the many taxes and fees included in the Affordable Care Act (ACA) when it first passed was the Patient-Centered Outcomes Research Institute (PCORI) fee. This was an annual fee based on the average number of members enrolled on the health plan, paid either by the insurance company (in the case of a fully-insured health plan) or the employer (in the case of a self-funded health plan, including Health Reimbursement Arrangements, or HRAs). In December of 2019, the Further Consolidated Appropriations Act was signed into law, extending the PCORI fee for another 10 years.
If you have a non-calendar year plan, the answer is maybe. If you have a calendar year plan, however, your filing deadline has not been affected, it remains July 31, 2020 (at least for now, barring further relief from the IRS). To see how your non-calendar plan may be affected, continue reading below. For more information on how to avoid errors and ERISA penalties as you file Form 5500 for your health and welfare plans, read our article The Form 5500 filing deadline is approaching - avoid errors and ERISA penalties.
Our previous article Open enrollment is over — now what? included a number of post-enrollment “bugaboos” that employers must keep in mind before considering themselves done with open enrollment-related activities for another year, including what to do if your third-party administrator (TPA) has not yet provided a new summary plan description (SPD). This article will address in more detail what you should expect to receive, and what you need to do with that information.
The creditable status of your prescription drug coverage is based on how it compares to Medicare Part D prescription drug coverage. If the prescription drug coverage you offer is at least as good as the coverage offered under Medicare Part D, your coverage is “creditable.” If not, your prescription drug coverage is considered “non-creditable.” How do you know if the coverage you offer is at least as good as Medicare Part D?
The July 31 Form 5500 filing deadline for calendar-year ERISA plan sponsors is right around the corner. You may think you have all of your ducks in a row, but employers sponsoring health and welfare plans often make common errors which can lead to hefty penalties. It’s worth your time to take a closer look and make sure none of your ducks have gone astray.
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