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ErisaALERT2011-18 HHS issues bulletin on Essential Health Benefits

Posted on December 10, 2011 by Mary Andersen in Uncategorized

Snapshot PPACA requires that health insurers offering coverage in the individual or small group health insurance markets include essential health benefits beginning January 1, 2014. There are 10 required categories of services in the essential health benefits package. On December 16, 2011 HHS issued an Informational Bulletin announcing that it intends to propose that essential […]

ACA, EHB, essential health benefits, HHS

ErisaALERT 2011-17 IRS revises Interim Policy on Electronic Disclosures

Posted on December 9, 2011 by Mary Andersen in Uncategorized

Snapshot In ErisaALERT 2011-13, we discussed Technical Release 2011-03, an interim enforcement policy regarding electronic delivery of the required participant disclosures until further guidance becomes available. Technical Release was intended to provide guidance related to DOL regulations issued in October 2010 regarding disclosures for participant directed accounts. The participant disclosures are plan related and investment […]

Disclosure, electronic disclosure, ERISA, IRS

ErisaALERT 2011-16 DOL and HHS issue guidance on ML Rrebates

Posted on December 4, 2011 by Mary Andersen in Uncategorized

On December 2, 2011, the DOL issued Technical Release 2011-04 concurrently with HHS issuance of an Interim Final Rule regarding Medical Loss Ratio (MLR) rebates. The Interim Final Rule appeared in the December 7, 2011 Federal Register and requests comments no later than February 6, 2012. The HHS guidance is expressed in terms of “subscribers” […]

ACA, DOL, minimum loss rebates, MLR

ErisaALERT 2011-15 DOL issues final regs investment advice

Posted on November 18, 2011 by Mary Andersen in Uncategorized

On October 25, 2011 the DOL issued a final rule relating to the provision of investment advice to participants and beneficiaries in individual account plans and beneficiaries of individual retirement accounts (and certain similar plans). This ALERT will focus on employer sponsored individual account plans. Background The Pension Protection Act of 2006 created a statutory […]

DOL, investment advice

ErisaALERT 2011-14 W-2 reporting revisited

Posted on November 8, 2011 by Mary Andersen in Uncategorized

 Form W-2 Reporting As described in ErisaALERT 2011-5, the Affordable Care Act required informational reporting of the aggregate cost of employer sponsored group health plan coverage beginning with 2012 W-2s issued in January 2013. On October 31st, the IRS conducted an informative webinar which should be available shortly on their website. In addition, the IRS […]

ACA, w-2 reporting

ErisaALERT 2011-13 Interim Policy on Electronic Disclosures

Posted on October 1, 2011 by Mary Andersen in Uncategorized

Snapshot In October 2010, the DOL issued regulations regarding disclosures (referred to as “participant disclosures” in this ErisaALERT) in participant directed accounts. The participant disclosures are plan related and investment related with each category requiring certain expense related disclosures. Certain participant disclosures can be provided in the summary plan description and/or the pension benefit statement […]

Disclosure, DOL, interim policy on electronic disclosures

ErisaALERT 2011-12 Summary of Benefits and Coverages Part II

Posted on August 21, 2011 by Mary Andersen in Uncategorized

Bottom line: As noted in Part I, a summary of benefits and coverages (SBC) must be provided to health plan participants and beneficiaries. The SBC consists of a 4 page (double sided) summary in a prescribed format and includes a glossary of terms as well as examples of how certain conditions will be covered by […]

ACA, SBC

ErisaALERT 2011-11 Summary of Benefits and Coverages

Posted on August 18, 2011 by Mary Andersen in Uncategorized

Bottom line: Effective March 23, 2012, a summary of benefits and coverages (SBC) must be provided to health plan participants and beneficiaries. The SBC consists of a 4 page (double sided) summary in a prescribed format and includes examples of how certain conditions will be covered by the plan. A separate glossary of terms is […]

ACA, SBC

ErisaALERT 2011-10 Coverage of preventive services for women

Posted on August 14, 2011 by Mary Andersen in Uncategorized

Bottom line: For plan years beginning on or after August 1, 2012, new plans and non grandfathered plans must offer with no cost sharing, certain preventive care and screenings for women. Exemptions may be allowed for certain religious employers. Background The Affordable Care Act (ACA) incorporates sections of the Public Health Services (PHS) Act into […]

ACA, women’s preventive services

ErisaALERT 2011-08 IRS issues 2009 Form 8955-SSA

Posted on June 11, 2011 by Mary Andersen in Uncategorized

Quick Summary The IRS has issued the 2009 Form 8955-SSA and extended the due date for the 2009 and 2010 Form 8955-SSA to the later of January 17, 2012 or the due date that generally applies for filing the 2010 Form 8955-SSA. The 2010 Form 8955-SSA has not been issued. The January 17, 2012 due […]

8955 SSA, Form 5500, Form 8955 SSA, IRS, Reporting
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