(303) 369-3200

Monday, 09 May 2016 03:18

HSA Contribution Limits for 2017 Set

On April 29, 2016, the IRS provided inflation-adjusted HSA contribution limits for 2017, as well as the HDHP minimum deductible and maximum-out-of-pocket expenses associated with HSA's. Click here for the IRS publication.  
 
The contribution limits for HSA's in 2017 will increase by $50 for self-only coverage.  Family contributions to HSA's will remain unchanged, as will the minimum deductible and maximum-out-of-pocket expenses for the High Deductible Health Plans (HDHP).  All changes are based on cost-of-living adjustments determined by the IRS.
 
A comparison of the last several years is shown below:
Published in Compliance

Have you ever experienced billing or invoice issues? Frustrated with people you already terminated still showing up on your bill? Look no further as your Fall River team is here to help! 

When processing eligibility changes such as enrollments, changes or terminations, you can follow these three simple steps to improve the accuracy of your carrier bills. 

Step 1 – Process On Time

  • If you have an impending enrollment, change or termination, it is best to get these submitted to the carrier as soon as possible to prevent any processing delay. The cutoff for the next bill is often 2-3 weeks before the end of the month, which is why people you’ve already terminated can still be showing up if you didn’t terminate them soon enough.  If you want a person who’s terminating on 3/31, for example, to NOT be on your April bill, you may need to get that done as soon as 3/10, depending on your carrier and the billing cycle dates you’ve selected.
  • If terminations are not submitted prior to the actual termination date, carriers do have the right to bill you for the following month of coverage. It’s the most common billing issue and unfortunately, there’s not much that can be done about it. In the Colorado fully insured market for groups with 2-99 employees, carriers will not allow terminations after the effective date unless proof of other coverage is provided.  So, that 3/31 term MUST be done on or before 3/31, otherwise you may be tracking down a copy of the employee’s next ID card before the term can be done.

Step 2 – Process Online

  • Most carriers offer an Online Employer Portal for managing eligibility and paying premium invoices. The fastest way by far to process any eligibility enrollment, change or termination is to complete them online, as most carriers will update their systems in real-time or within 24 hours of the transaction. If you need help obtaining a login and password for an Employer Portal or would like additional training for your carrier-specific portal, please contact your Fall River Account Executive.
  • Billing and invoicing cycles vary from carrier to carrier. The invoice should show your due dates, remittance details (including overnight payment or wire transfer options) and/or other carrier-specific instructions. 
  • If you have signed up to receive electronic invoices, carriers will typically email you in advance when the invoice is ready to view. But watch out…sometimes these emails will appear in your junk folder and could go unnoticed unless you check that folder regularly. 

Step 3 – Audit Your Bill 

  • As soon as you receive your premium invoice, whether paper or electronic, try to reconcile it with your records as soon as possible - the sooner the better while it is still fresh in your mind. If you notice any concerns, reach out to your Fall River Account Executive and we can help you get it resolved. Clients have called us after finally noticing errors that have been on the bill for many months – it is very difficult to help you get your money back if too much time has passed.
  • Most carriers do not allow self-adjusting and require that you pay your invoice as billed.  There can be serious consequences to short-paying your bill, up to and including termination.  If there are folks on your invoice you’ve already terminated, the invoice will auto-adjust next month to credit the premiums back.
  • If payments aren’t received within the 31 day grace period, carriers may terminate coverage and it can be difficult to reinstate. To prevent a lapse in coverage, make payments by the due date or call the carrier to discuss financial arrangements, and don’t self-adjust (ie short-pay) your bill. 

We hope these tips are helpful – please feel free to call us at any time at 303.369.3200 with any billing challenges you may be having.

Published in Best Practices
Mile High SHRM PDG featuring Kristen Russell and Dean Heizer
Thursday, June 25th, 3-5 pm
CSU Downtown, 475 17th Street Suite 300, Denver, CO 80203

There are so many laws driving your practices regarding HR and Benefits, that it's getting tougher and tougher to keep track of them all. Yet with the threat of significant fines and even jail time for violations, you’ve got to stay on top of the most important ones.

Join us for a high energy and entertaining pick-me-up to the end of your day as we review the most common mistakes that land an HR person in trouble, especially regarding your employee benefits.  We'll cover what you thought you knew, but might be surprised about, on the following topics:

  • ERISA – it’s not just for retirement plans, as the DOL is auditing more and more health plans.  We’ll cover some classic retirement plan blunders, but also what you need to do on your health plan – and why so many employers are out of compliance!
  • HIPAA Discrimination Rules and how to keep your wellness program legal based on all the latest guidance (click here for more topics and to register)
  • The ADA as it impacts wellness and workers comp and wellness programs;
  • COBRA goofs you might just have made at one time or another; and 
  • Tricky situations under disability leave and the FMLA.

Towards the end we'll have time for sharing best practices among peers, and networking, accompanied by some adult refreshments. Who knew Happy Hour could be so fun AND educational??  This program is free for Mile High SHRM members, and very affordable for others.  Register here.

 

Published in Best Practices
Monday, 30 March 2015 07:30

The End of Transition Relief

Are your health plans compliant with the Affordable Care Act (ACA)?  If you are a small employer that has put off making the switch and have kept your non-compliant plans under “transition relief,” also known as “Grandmothering,” this grace period has come to an end and your next renewal will be onto an ACA compliant plan.

The Colorado Division of Insurance (DOI) announced on March 13th, 2015 that Individual and Small Group plans not considered to be ACA-compliant will not be allowed to continue into 2016.  Insurance companies will no longer offer non-compliant plans during your 2015 renewal, and you’ll need to choose new plans that are ACA-compliant.  The only exception is if you have grandfathered plans and are not yet subject to this provision of the Affordable Care Act.

Fall River will be reaching out to all of our small group clients with Grandmothered plans to help them convert to ACA-compliant plans by the end of 2015. 

More History.  In March 2014, President Obama announced the transition relief provision that allowed the states to choose whether to allow the continuation of non-compliant plans for two more years.  In May of 2014, Colorado chose to allow non-compliant plans in late 2014, into 2015, to allow individuals and small groups more time to prepare for the transition.  At the time the Insurance Commissioner, Marguerite Salazar, felt that employers, carriers, and consumers would benefit from having additional time to prepare for the new ACA plan requirements.  However this year she stated that in her opinion all involved have had time to get ready and that it was time to implement the ACA-compliant plans. The recent decision does impact a few hundred thousand people in Colorado that are in either insured under Individual or Small Group plans that are not yet ACA-compliant.  

What happens next?  Insurance carriers will notify the individuals and small employers covered under non-compliant plans of their discontinuation in 2015.  The notice of termination should be provided at least 90 days before the termination of the plan.  Companies will be provided with information about alternate ACA-compliant plans for consideration upon renewal.  For Individuals losing their non-compliant plan, the loss of their existing coverage is considered a qualifying event to take advantage of the special enrollment period to select new coverage on the Exchange or directly through the carrier.

Small Business Renewal Dates.  Many small companies (2-50 employees) moved their renewal date to the very end of the year to delay the impact of the ACA-compliant plans as long as possible.  However, so many renewals are now in the last quarter of the year that it’s hard to get the carriers’ attention.  If your business ideally does not want to have a renewal date in November or December, you may wish to consider moving your renewal date in 2015 or 2016, if your carrier allows it.  We can help you evaluate whether this would be the right strategy for us – just This email address is being protected from spambots. You need JavaScript enabled to view it. or give us a call!  

Published in Healthcare Reform
Sunday, 22 March 2015 18:00

Healthcare Cost Management Strategies

Are you paying more and more for worse benefits? While some aspects of rising healthcare costs are driven by factors outside our control, there are MANY factors within our control, even for smaller employers.  The problem is that the strategies used by many brokers aren’t sustainable.

Learn how employers of all sizes can manage their health care costs down, by taking an out-of the box approach in multiple areas. Register now for our webinar on Tuesday, May 19th, to start taking charge of the cost factors you CAN control.

 

Published in Best Practices

The IRS recently released IRS Notice 2015-17 to give more guidance to small employers (less than 50 full time equivalents) who do not offer healthcare coverage, but do reimburse employees for the cost of their premiums when those employees purchase health care coverage on their own.

The IRS gave previous guidance that defined Employer Payment Plans in IRS Notice 2013-54, and indicated that a stand-alone plan that directly paid for or reimbursed employees for health insurance obtained elsewhere (including Medicare), would not be compliant with the Affordable Care Act, and would be subject to an excise tax (Section 4980D) of up to $100 per employee per day.  

What does Notice 2015-17 accomplish and whom does it affect?

  1. Small Employers with an Employer Payment Plan will receive transition relief until July 1, 2015 from the Code 4980D Excise Tax, and from the responsibility to file Form 8928 (utilized to self-report violations and compute the penalty tax)
  2. Transitional relief will ONLY apply to small employers who are defined as an employer who is NOT considered Applicable Large Employers (ALEs) and does NOT average more than 50 full-time employee (including full-time equivalent employees)
  3. Transition relief will be extended to June 30, 2015. Beginning July 1, 2015, an employer who does not comply may be subject to the penalties

According to the Notice, “This relief does not extend to stand-alone HRAs or other arrangements to reimburse employees for medical expenses other than insurance premiums.” So, if your company has an arrangement where no group insurance is provided but actual out-of-pocket medical expenses are reimbursed, this plan should be discontinued immediately, and if needed, any violation after 1/1/2014 should be self reported.

Employers with Employer Payment Plans not currently in compliance with the market reforms should take the necessary steps now to bring their plans into compliance. 

In the past, many were under the belief that it was OK to reimburse for individual or Medicare Premiums as long as it was post tax.  Now, it’s clear this has changed, if the employer requires proof of purchase of coverage.  The IRS’s treatment of increases in employee compensation to assist with insurance cost is spelled out as follows:

  • Employers who increase an employee’s taxable compensation and do not require that the additional compensation be used to purchase health insurance coverage do NOT create an Employer Payment Plan and are NOT considered to have a group health plan

  • If an employer requires that an employee uses the increased compensation to purchase health coverage, this does create an Employer Payment Plan and is subject to the excise tax (Section 4980D), EVEN if the payment is taxable

Medicare premium reimbursement arrangements (for Medicare Part B or D) for active employees are considered an Employer Payment Plan, and they are subject to the ACA market reforms if they cover two or more active employees. Thus, such reimbursement arrangements are not allowed.  Employers wishing to encourage employees over 65 to move over to Medicare may wish to consider a taxable and unconditional increase in compensation for those who opt off of the group medical plan, especially if more than one employee is affected.

The Notice also provided guidance for the tax treatment of the health insurance premiums of S-Corporation owners as well as certain Medicare and TRICARE-related reimbursements.  See the Notice itself for more details

Here are our recommendations:

  • Employers who have not been offering premium reimbursement plans need not take any action

  • Small employers who have been paying directly or reimbursing premiums for individual insurance contracts must stop doing so no later than June 30, 2015, to avoid the possibility of an excise tax (Section 4980D)

  • Employers who are paying Medicare premiums or reimbursement for more than one active employee should also cease this practice

  • If the employer wishes to continue helping employees with the cost of coverage, payments conditioned on proof of coverage should be converted to unconditional and taxable compensation increases

  • Employers with 50 or more Full Time Equivalent employees should immediately review any Employer Payment Plans to ensure they do not contain reimbursement for premiums and cease any pre- OR post-tax reimbursement practices they have in place

Disclaimer.  Please remember that the information we provide is not to be construed as legal advice. For further interpretation of how this topic specifically affects your group health plan, we always suggest checking with an ERISA attorney. 

 

Published in Healthcare Reform
Thursday, 05 March 2015 11:59

Supreme Court Hears ACA Subsidy Challenge

In a much watched case, the Supreme Court heard arguments yesterday about a provision that could eliminate the Affordable Care Act (ACA) individual market premium assistance, depending on how it is interpreted by the Court.  This would affect the roughly 70% of states who have not established their own exchange; please note that Colorado is NOT one of the states affected. The provision relates to language in the ACA that indicates subsidies for low-income individuals are available on “Exchanges established by the states.”  The debate is between a literal reading of that language, or looking at the larger context of what Congress intended.

 

A ruling is not expected until late June, but expert opinion appears to be leaning slightly in favor of predictions that the Supreme Court will uphold the subsidies as currently implemented.  If it goes the other way, an estimated 7.5 million Americans in those states who did not choose to set up their own Exchange will lose access to subsidized coverage.  If too many of them choose to not purchase coverage as a result, it will likely raise premiums for those remaining, and may destabilize the individual insurance marketplaces in those states.

 

Keep in mind there is NO impact on insurance in Colorado, regardless of the outcome of the case.

Published in Healthcare Reform
Wednesday, 18 February 2015 17:00

Should You Survey Your Employees About Benefits?

An employee survey can give you some great insight into what employees think about your current benefit package, but could you also be setting yourself up for negative responses and backlash?  There are both pros and cons of asking your employees to complete a benefit survey.

One of the best reasons to do a survey is to gauge your employees’ satisfaction level with the current benefit package offered at the company.  Are there benefits that are glaringly missing in your package that would increase their satisfaction?  Are there benefits being offered that are not important to employees and possibly being underutilized?  You can even have your employees rank the separate benefits in the order of importance to them.  

If you are a smaller group or fully insured, an employee survey may be the only way to find out what your medical utilization is on your plans.  You can ask employees to answer questions about whether they met their deductible or out-of-pocket maximum that year.  You can ask how many times they go to the doctor for preventive care visits or for illness.  You can also ask how many prescriptions they fill in a month and what the average cost of those medications is.  This information can then be used to target certain plan features that may better fit the needs of your population.

If you are thinking about implementing a wellness program, you can also find out what type of services and programs your employees might value most.

One of the drawbacks of doing a survey is that if you ask what employees want, it may create an expectation that they will get what they ask for.  If the budget is tight that year and the requested benefits can’t be offered, there may be some dissatisfaction over that decision.  One way to solve this is to ask them to rank priorities or pose a tradeoff of what they would be willing to give up to get something else that is more important to them. If you ask about their personal plan utilization, you might receive a little grumbling.  We recommend three ways to cope with that:

  1.  Explain the reasons you are asking for personal info;

  2.  Stress that the survey is anonymous; and

  3.  Emphasize that you as the employer care about their benefits package and want to make sure the plans are meeting their needs.

Fall River offers employee surveys to our clients as part of our pre-renewal planning.  If a company is unsure about their next steps in the benefits arena, a survey can give valuable information about carrier or plan changes that need to be made, employer contribution changes to consider, and benefits that should be added or done away with.  We will often do a survey for our new clients, which many times reveal problems that have not been addressed in the past.  Companies can sometimes uncover areas of spending on one item that could be better spent on a benefit that employees value much more.  

In our experience, the risk of doing an employee survey is usually outweighed by the beneficial information you receive.  Feel free to This email address is being protected from spambots. You need JavaScript enabled to view it. for more ideas and suggestions on making a survey work for your group!

 

Published in Best Practices
Monday, 03 November 2014 17:00

Do You Need to Amend your FSA Plan?

Many employers have calendar year Flexible Spending Account (FSA) plans even if their benefits renew in a different month.  Just a reminder this time of year – you may need to amend your FSA plan document as your plan anniversary approaches.  Here are three reasons you may need to make a change:

  • You want to take advantage of the inflation indexing on the Healthcare FSA.  Beginning January 1, 2015, the annual allowable dollar limit for employee contributions for Healthcare Flexible Spending Accounts (FSAs) will increase $50 to $2,550. Plan sponsors are not required to adopt the new limit; however, for those employers-sponsored plan who will offer the increase an amendment to the Section 125 plan document will be needed. 
  • You want to take advantage of the $500 Rollover Provision.  Last year the Treasury Department and the IRS modified the “use-it or lose-it” rule for the FSA. Plan participants are now allowed to carryover up to $500 of their unused balances into the next plan year. If you didn’t take advantage of this last year, you may wish to amend your plan document this year to do so. 
  • You want to add a grace period.  If you are not using the $500 Rollover, you may add a Grace Period.  This allows employees to incur additional expenses during the first 2 ½ months of the next plan year to spend any unused funds from the current plan year. This is in addition to the “run out” period that all plans have to submit receipts after the expenses are incurred.

Keep in mind that plans cannot offer both a grace period and the $500 rollover at the same time. It must be one or the other. The only time that both would ever apply would be if an employer-sponsored plan had the Healthcare FSA set up as a rollover option, but with a grace period  on the Dependent Care Assistance Program (DCAP).   

Whichever option you choose, be sure to amend your Section 125/FSA plan document! 

Published in Best Practices
Thursday, 25 September 2014 08:13

What is your Healthcare Strategy Score?

The Affordable Care Act aside, employers everywhere are struggling with the rising cost of healthcare.  Even though annual trend levels have tapered off, the costs were already so high that adding even one extra dime to healthcare costs can feel like the straw that broke the camel’s back.

There are some factors affecting your healthcare costs that you don’t control.  But what about those you CAN control?  Are you taking advantage of all of the potential ways you can engage your employees as consumers, help them get healthy, and then use creative funding strategies to capture the resulting savings? 

First of all, you’ll want to check out our Tackling Healthcare Costs webinar next Tuesday, October 7th, at 10 am.  But also, you’ll want to take advantage of Fall River’s new Healthcare Strategy Score system, where we meet with you to benchmark how proactive and creative your current strategies are on a scale of zero to 100%, then lay out a game plan of how you can up your score and save on your costs as a result.

 

Request your Healthcare Strategy Score now!

Published in Best Practices
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