Individual Coverage HRAs – Paying Individual Insurance Premiums

Individual Coverage HRAs – Paying Individual Insurance Premiums

Beginning in 2020, employers of all sizes may implement a new HRA design – an individual coverage HRA (ICHRA) – to reimburse their eligible employees for insurance policies purchased in the individual market or Medicare premiums.

Final rules released by the Departments of Labor, Health and Human Services (HHS) and the Treasury (Departments) permit employers to offer an ICHRA as an alternative to traditional group health plan coverage, subject to certain conditions. One of these conditions is that employees and dependents who are covered by an ICHRA must be enrolled in individual insurance coverage or Medicare coverage for each month they are covered by the ICHRA. Also, employers that sponsor ICHRAs must comply with an annual notice requirement.

Employers may allow employees to pay for off-Exchange health insurance on a tax-favored basis, using a Section 125 cafeteria plan, to make up any portion of the premium that is not covered by the employer’s ICHRA. (more…)

HSA/HDHP Limits Increase for 2020

HSA/HDHP Limits Increase for 2020

The IRS released Revenue Procedure 2019-25 to announce the inflation-adjusted limits for health savings accounts (HSAs) and high deductible health plans (HDHPs) for 2020. These limits include:

  • The maximum HSA contribution limit;
  • The minimum deductible amount for HDHPs; and
  • The maximum out-of-pocket expense limit for HDHPs.

These limits vary based on whether an individual has self-only or family coverage under an HDHP.

The IRS limits for HSA contributions increase for 2020. Eligible individuals with self-only HDHP coverage will be able to contribute up to $3,550 for 2020, while eligible individuals with family HDHP coverage will be able to contribute up to $7,100 for 2020. The HDHP cost-sharing limits also increase for 2020. (more…)

Final Notice of Benefit and Payment Parameters for 2020

Final Notice of Benefit and Payment Parameters for 2020

The Department of Health and Human Services (HHS) released its final Notice of Benefit and Payment Parameters for 2020. This rule describes benefit and payment parameters under the Affordable Care Act (ACA) that apply for the 2020 benefit year. Standards included in the rule relate to:

  • Annual limitations on cost sharing;
  • The individual mandate’s affordability exemption;
  • Direct enrollment in the Exchanges; and
  • Special enrollment periods in the Exchanges.

HHS also sought comments on issues to address in the future, such as the practice of “silver loading,” the automatic re-enrollment process through the Exchanges and any additional measures that would reduce eligibility errors and potential government misspending. Although the final rule does not finalize any policies related to these issues, HHS noted that it intends to take the comments received in response to the proposed rule into consideration in future rulemaking. (more…)

DOL Clarifies Employer Obligation to Designate FMLA Leave

DOL Clarifies Employer Obligation to Designate FMLA Leave

The Family and Medical Leave Act (FMLA) provides eligible employees with unpaid, job-protected leave for specified family and medical reasons. Eligible employees may take up to 12 weeks of leave (26 weeks for military caregiver leave) each year for FMLA-qualifying reasons. Because FMLA leave is unpaid, employees often request time off under another leave program, such as paid sick leave or paid time off (PTO).

An opinion letter from the Department of Labor (DOL) clarifies that employers cannot delay designating paid leave as FMLA leave, even if the employee would prefer this delay. Employers must notify employees that their leave is FMLA-protected within five days of obtaining enough information to make this determination. (more…)

The State of the Union Address and the Employee Benefits Market

The State of the Union Address and the Employee Benefits Market

On Tuesday, Feb. 5, 2019, President Donald Trump delivered the 2019 State of the Union Address (SOTU). The SOTU is an annual message delivered by the president to a joint session of Congress at the beginning of each year. At this year’s SOTU, President Trump discussed issues that have the potential to impact the employee benefits industry, including pre-existing conditions, lower prescription drug prices and nationwide paid family leave. (more…)