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,...

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...

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,...