Newsletters - May 9, 2013

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Questions & Answers for Employers

The GBS comprehensive Questions & Answers for Employers is a continually updated document addressing the questions most frequently asked by our clients. This document is updated as new regulations are released or we learn more information about a Healthcare Reform topic. By clicking on this link you will always have access to the most recent version and the most up-to-date answers.

To access the FAQs please click here.

Healthcare Reform Update - May 9, 2013

Regulators Issue Much Anticipated Guidance on the Notice of Exchanges (Marketplaces) to Employees

In a technical release, issued late in the day on May 8, the Department of Labor (the "DOL") provided temporary guidance regarding the notice employers must provide to employees about their options under health insurance Exchanges (currently rebranded as "Marketplaces").

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IRS Releases Proposed Regulations on Minimum Value and Affordability for Wellness Programs, HSAs and HRAs

On May 3rd, the Internal Revenue Service ("IRS") issued a Notice of Proposed Rulemaking ("NPRM") with guidance on the determination of Minimum Value ("MV") and "Affordability" for coverage under employer-sponsored health plans. The NPRM is consistent with the final MV regulations and MV Calculator issued by the Department of Health and Human Services ("HHS") in February 2013, but contains additional insight on how the IRS intends to treat wellness programs, HSAs and HRAs. In addition, the preamble to the NPRM contains three safe harbor plan designs currently being considered by the IRS. Lastly, the NPRM builds upon the IRS' May 2012 premium tax credit regulations by clarifying how the premium tax credit will be calculated in certain situations, such as those involving partial months of coverage.

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Departments Release FAQs Offering SBC Guidance and Update Templates

On April 24, 2013, the Departments of Labor, Health and Human Services, and the Treasury ("Departments") issued the fourteenth set of Frequently Asked Questions ("FAQs") intended to assist with the implementation of the Patient Protection and Affordable Care Act ("PPACA") focusing entirely on the Summary of Benefits and Coverage ("SBC"). The most salient guidance from the FAQs has to do with updated SBC templates and extended relief. This article discusses these, as well as the other, issues addressed by the FAQs.

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Certificates of Creditable Coverage Are Going Away! -But Not Yet

The Patient Protection and Affordable Care Act ("PPACA") prohibits the use of pre-existing condition limitations by group health plans (other than excepted benefits) beginning in 2014. However, the change is not universally effective on January 1, 2014. The requirement to eliminate pre-existing condition limitations plans applies based on the plan year. The effective date for a calendar year plan will be January 1, 2014.

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New PPACA Implementation FAQs Offer Guidance on Range of Issues Including Clinical Trials

On April 29, 2013, the Departments of Labor, Health and Human Services, and the Treasury ("Departments") released the fifteenth set of frequently asked questions ("FAQs") on the implementation of the Patient Protection and Affordable Care Act ("PPACA"). These FAQs discuss participating in clinical trials, waivers to the annual limit restrictions, provider nondiscrimination, and transparency reporting.

To read more, please click here.

HHS Attempts to Simplify Individual and Family Applications for Marketplaces

Although questions remain surrounding the establishment of the Health Insurance Marketplaces (formerly referred to as Exchanges) developed by PPACA, HHS recently finalized the applications for individuals and families to use when applying for health coverage from a Marketplace. Employers will want to take note of the applications, particularly the Family application, which requires applicants to obtain information from their employer. Moreover, it is assumed that curious employees may ask their employer questions about applying for coverage from a Marketplace. The application will be the starting point for individuals and families seeking health insurance from a Marketplace, Medicaid, and the Children’s Health Insurance Program, as well as, those seeking tax credits to assist with premium payments.

To read more, please click here.

CMS Sets Termination Dates in Anticipation of ERRP Wind Down

A recent notice set forth termination dates for certain operational processes of the Early Retiree Reinsurance Program (“ERRP”). ERRP was developed by PPACA as a temporary, transitional program to bridge the gap between the passage of PPACA and when its major initiatives take effect. ERRP provides reimbursement to eligible sponsors of employment-based plans for a portion of the costs of providing health coverage to early retirees (and their eligible spouses, surviving spouses, and dependents). ERRP was funded with $5 billion and the program was scheduled to end on January 1, 2014 (the sunset date) even if the entire sum was not used.

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GBS Benefits Strategy and Benchmarking Survey Closes on May 17

Don’t miss out! If you’ve already signed up, be sure to complete your Gallagher Benefits Strategy and Benchmarking Survey before Friday, May 17, 2013. In return for completing your survey, you will receive a complimentary executive summary containing Gallagher’s strategic analysis of the current state of the market and an overview of the national data.

If you’ve lost your login information or have any other questions about the survey, please contact Andy_McNulty@ajg.com for more information.