2016 Transitional Reinsurance Fee Form Now Available
By November 15, 2016, employers with self-insured medical plans must report annual enrollment counts to Health and Human Services (“HHS”) in order to pay the 2016 Transitional Reinsurance Fee. Now in its final year, the fee for 2016 is $27 per covered life per year.
HHS Penalties Increase
On September 6, 2016, the Department of Health and Human Services (“HHS”) issued an interim final regulation that adjusts civil penalties for inflation. The interim final regulation does not follow the usual procedures that offer a notice and comment period. As such, a Notice of Proposed Rulemaking has not been issued and a comment period is not provided due to potential delay in the applicability of the regulation.
Medicare Part D: Reminder to Distribute Creditable Coverage Notice
Employers who sponsor a group health plan with prescription drug benefits are required to notify their Medicare-eligible participants and beneficiaries as to whether the drug coverage provided under the plan is "creditable" or "noncreditable." This notification must be provided prior to October 15th each year.
Opt-Out Bonuses May Affect Affordability
On July 8, 2016, the Internal Revenue Service (IRS) issued proposed regulations that, among other things, address affordability determinations for individuals who are eligible for employer-sponsored health coverage. This proposed rule builds on earlier guidance, Notice 2015-87, describing the effect an opt-out payment has on affordability.
ACA Section 1557 Nondiscrimination Provisions Affect Group Health Plans
On May 18, 2016, the Department of Health and Human Services (HHS) Office of Civil Rights (OCR) published a final rule implementing Section 1557 of the Affordable Care Act (ACA). Section 1557 prohibits discrimination in health care programs or activities on the basis of race, color, national origin, sex, age, or disability. Notably, this rule expands on prior civil rights law to prohibit sex discrimination in health care.
Health Reform Calculators
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If you are an individual seeking health insurance or your employer works with MBA, continue to our individual section for information on the resources available to you and your family.
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