We’d like to remind you of some upcoming deadlines and other important announcements that may impact your plan.
- The January 15 deadline is approaching for the transitional reinsurance fee payment. Employers with applicable health plans will need to submit the first installment of their 2015 payment to the Department of Health and Human Services (HHS) by January 15, 2016. This is a temporary fee for the years 2014–2016, and is designed to stabilize premiums in the individual market, both in and out of the marketplace. The amount of the fee for 2015 was $44 per covered life. The payment may also be made in full by the deadline. You can read more about this fee in our summary found here.
- The January 31 deadline is approaching for W-2s and 6055/6056 individual notices. January 31, 2016, will be here before you know it. As a reminder, employers must have their employees’ 2015 W-2s and 6055/6056 individual notices postmarked by this date. They may be sent in the same mailing. For more information, please refer to our prior reminder here.
- PCORI fee amount. The IRS announced that the Patient-Centered Outcomes Research Institute (PCORI) fees are to be used for plan years that end between October 1, 2015– September 30, 2016. The amount of the fee is $2.17 per covered life. The fees collected are be used to fund clinical outcomes effectiveness research. The fee is temporary and applies to plans with plan years ending on or after September 30, 2012, and before October 1, 2019.The fee in future years is subject to adjustment for projected increases in national health expenditures. For more information related to the PCORI Fee please refer to your Healthcare Reform Guide.
- Automatic enrollment repealed. The automatic enrollment mandate of the Affordable Care Act (ACA) was repealed on October 28, 2015. The mandate would have required employers with 200 or more full-time employees to automatically enroll all new employees and to continue the enrollment of current employees in group health coverage. Due to its repeal, plans will not need to comply with this provision.
- Clarification to existing preventive services. The Departments of Labor, Health and Human Services and the Treasury have issued Frequently Asked Questions (FAQs) related to the preventive services mandate. These FAQs contained an important clarification of breastfeeding equipment, which is now required to be covered for the duration of breastfeeding and plans may not require that the equipment be obtained within a certain time period following birth.
Our systems have been updated to take into consideration that these breastfeeding benefits must be available for the duration of breastfeeding and cannot be limited to 60 days post delivery. You should review your plan document to see if these changes impact your Summary Plan Description (SPD). Meritain Health SPDs will be updated at renewal when the 2016 healthcare reform amendments are issued. Your Meritain Health written plan document contains a statement that your document will automatically update when rules and guidance in relation to preventive services are issued. If you’d like an amendment sooner, please contact your client relations team.
As a reminder, under healthcare reform, non-grandfathered health plans must provide coverage with no cost sharing (no copays, deductibles or coinsurance can be imposed) for certain in-network recommended preventive services.
Please contact your client solutions team if you would like to receive our current preventive services flyers for members.
- Final regulations issued related to benefit reforms implemented in 2010. Recently, the IRS, Department of Labor, and the Department of Health and Human Services released final regulations for various aspects of healthcare reform. Interim final rules have been in effect since 2010 and the final regulations simply merge the existing rules with follow-up guidance. For example, the final rules clarify that the prohibition of dollar limits on Essential Health Benefits (EHB) applies to out-of-network benefits. These regulations apply beginning with the first plan year on or after January 1, 2017. There is no action required to be in compliance by that time, unless your plan places dollar limits on out-of-network EHBs. In that case, you will need to amend your plan no later than the first day of the first plan year in 2017, to remove dollar limits placed on out-of-network EHBs. Plans may continue to place non-financial limits on EHBs, such as visit limits.
Compliance Quarterly is being provided as an informational tool. It is recommended that plans consult with their own experts or counsel to review all applicable federal and state legal requirements that may apply to their group health plan. By providing this publication and any attachments, Meritain Health is not exercising discretionary authority over the plan and is not assuming a plan fiduciary role, nor is Meritain Health providing legal advice.