Compliance Corner

Announcements

Podcast Episode 128: Fall Bills: Congress Considers Mental Health Services Proposals

October 11, 2022

In this episode, Suzanne Spradley and Chase Cannon walk through recent activity in the House and Senate relating to several new laws under consideration on coverage of mental health services. Suzanne starts by reviewing some potential changes relating to Medicare coverage of mental health services, such as required behavioral health monitoring for suicide ideations and the need for interventions such as detoxification for substance abuse. Suzanne and Chase walk through proposals from the House on coverage for forensic medical exams relating to sexual assault. Suzanne and Chase close with a discussion of provider network proposals and the Senate’s reauthorization of funding for the Jackie Walorski Maternal and Child Home Visiting Act, which promotes healthy pregnancy practices, language development and early learning at home.

Periodically, NFP's legal experts make the subject of compliance personal for a wide audience. By breaking down the daunting details of emerging policies and bridging the gap between legislation and what it means for the listener, Chase Cannon and Suzanne Spradley make compliance issues relatable and relevant. Visit our Soundcloud page for the most up-to-date episode.

Subscribe on iTunesListen on Google Play Music

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October Get Wise Wednesdays – Register Now

October 11, 2022

Topic: MHPAEA: Check Yourself Before You Wreck Yourself

The Mental Health Parity and Addiction Equity Act (MHPAEA) continues to be an enforcement priority for the Department of Labor. Still, many compliance questions remain. Join us as we review the law’s requirements, recent enforcement activity and notable litigation.

Time: October 19, 2022
2:00 to 3:00 p.m. CT (3:00 to 4:00 p.m. ET)

Register Now

This program is pending approval for 1.0 (general) recertification credit hours toward PHR, SPHR and GPHR recertification through the HR Certification Institute. For more information about certification or recertification, visit the HR Certification Institute website at hrci.org.

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Reminder: It’s MLR Rebate Time Again!

October 11, 2022

The ACA requires insurers to submit an annual report to HHS accounting for plan costs. If the insurer does not meet the medical loss ratio standards, they must provide rebates to policyholders. Rebates must be distributed to employer plan sponsors between August 1, 2022, and September 30, 2022. Employers should keep in mind that if they receive a rebate, there are strict guidelines as to how the rebate may be used or distributed. The plan asset portion of a rebate generally must be applied within 3 months of receipt by the employer, or the amount would need to be held in trust to comply with ERISA’s requirements.

For more information, please see our August 16, 2022, FAQ and contact your advisor for a copy of “Medical Loss Ratio Rebates: A Guide for Employers.”

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Reminder: Medicare Part D Notice to Employees Deadline Is October 14, 2022

October 11, 2022

Employers must notify individuals who are eligible to participate in their medical plan whether the plan’s prescription drug coverage is “creditable” or “non-creditable” as compared to Medicare Part D coverage.

As a reminder, the Medicare Part D notice of creditable coverage should be distributed to employees by October 14, 2022. This notice serves to inform Medicare-eligible individuals of whether or not their employer group coverage is creditable. That information is necessary to help such individuals avoid paying higher premiums (also known as late enrollment penalties) for Medicare Part D coverage.

Employers should consult with their service providers to determine whether their coverage is creditable using either the simplified determination method or actuarial analysis. Also, keep in mind that CMS provides a model notice for employers.

For further information, please ask your advisor for a copy of our "Medicare Part D Disclosures: A Guide for Employers" white paper.

Read More

Podcast Episode 128: Fall Bills: Congress Considers Mental Health Services Proposals

September 27, 2022

In this episode, Suzanne Spradley and Chase Cannon walk through recent activity in the House and Senate relating to several new laws under consideration on coverage of mental health services. Suzanne starts by reviewing some potential changes relating to Medicare coverage of mental health services, such as required behavioral health monitoring for suicide ideations and the need for interventions such as detoxification for substance abuse. Suzanne and Chase walk through proposals from the House on coverage for forensic medical exams relating to sexual assault. Suzanne and Chase close with a discussion of provider network proposals and the Senate’s reauthorization of funding for the Jackie Walorski Maternal and Child Home Visiting Act, which promotes healthy pregnancy practices, language development and early learning at home.

Periodically, NFP's legal experts make the subject of compliance personal for a wide audience. By breaking down the daunting details of emerging policies and bridging the gap between legislation and what it means for the listener, Chase Cannon and Suzanne Spradley make compliance issues relatable and relevant. Visit our Soundcloud page for the most up-to-date episode.

Subscribe on iTunesListen on Google Play Music

Read More

October Get Wise Wednesdays – Register Now

September 27, 2022

Topic: MHPAEA: Check Yourself Before You Wreck Yourself

The Mental Health Parity and Addiction Equity Act (MHPAEA) continues to be an enforcement priority for the Department of Labor. Still, many compliance questions remain. Join us as we review the law’s requirements, recent enforcement activity and notable litigation.

Time: October 19, 2022
2:00 to 3:00 p.m. CT (3:00 to 4:00 p.m. ET)

Register Now

This program is pending approval for 1.0 (general) recertification credit hours toward PHR, SPHR and GPHR recertification through the HR Certification Institute. For more information about certification or recertification, visit the HR Certification Institute website at hrci.org.

Read More

Reminder: It’s MLR Rebate Time Again!

September 27, 2022

The ACA requires insurers to submit an annual report to HHS accounting for plan costs. If the insurer does not meet the medical loss ratio standards, they must provide rebates to policyholders. Rebates must be distributed to employer plan sponsors between August 1, 2022, and September 30, 2022. Employers should keep in mind that if they receive a rebate, there are strict guidelines as to how the rebate may be used or distributed.

For more information, please see our August 16, 2022, FAQ and contact your advisor for a copy of “Medical Loss Ratio Rebates: A Guide for Employers.”

Read More

Reminder: Calendar Year SAR Must Be Distributed by September 30, 2022

September 27, 2022

Plans that are subject to ERISA and Form 5500 filing must distribute the Summary Annual Report (SAR) to participants within nine months of the end of the plan year; thus, a calendar year plan is generally required to distribute the SAR for the 2021 plan year by September 30, 2022. If the plan applied for an extension to the Form 5500 filing, the SAR is then due within two months following that filing.

The SAR is a summary of the plan’s information reported on Form 5500. If a plan is not subject to Form 5500 filing, then it is exempt from the SAR notice requirement — this would include church plans, governmental plans, and unfunded or insured plans with fewer than 100 participants. Also, large, unfunded self-insured plans are exempt from the SAR requirement even though they are subject to the Form 5500 filing requirement.

Please ask your advisor for a copy of our "Summary Annual Report: A Guide for Employers" white paper for more information.

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Reminder: Medicare Part D Notice to Employees Deadline Is October 14, 2022

September 27, 2022

Employers must notify individuals who are eligible to participate in their medical plan whether the plan’s prescription drug coverage is “creditable” or “non-creditable” as compared to Medicare Part D coverage.

As a reminder, the Medicare Part D notice of creditable coverage should be distributed to employees by October 14, 2022. This notice serves to inform Medicare-eligible individuals of whether or not their employer group coverage is creditable. That information is necessary to help such individuals avoid paying higher premiums (also known as late enrollment penalties) for Medicare Part D coverage.

Employers should consult with their service providers to determine whether their coverage is creditable using either the simplified determination method or actuarial analysis. Also, keep in mind that CMS provides a model notice for employers.

For further information, please ask your advisor for a copy of our "Medicare Part D Disclosures: A Guide for Employers" white paper.

Read More

Podcast Episode 127: Benefits Aspects of the Inflation Reduction Act

September 13, 2022

In this episode, Chase Cannon and Suzanne Spradley discuss the benefits provisions of the recently-enacted Inflation Reduction Act. Chase walks through the extension of premium tax credit expansions through 2025, and the impact on employers with respect to the employer mandate penalties. Next, Chase and Suzanne discuss Medicare prescription drug cost reductions and a formalization of prior IRS guidance that allows HDHP coverage of insulin in certain circumstances without impacting HSA eligibility. The two close the podcast by outlining the new law’s increased funding of the IRS and how that might impact compliance enforcement on employer group health plans.

Periodically, NFP's legal experts make the subject of compliance personal for a wide audience. By breaking down the daunting details of emerging policies and bridging the gap between legislation and what it means for the listener, Chase Cannon and Suzanne Spradley make compliance issues relatable and relevant. Visit our Soundcloud page for the most up-to-date episode.

Subscribe on iTunesListen on Google Play Music

Read More

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