Comments on Adult Child Coverage

We continue to receive questions from our clients about the scope of coverage for adult children.  Although the tax guidance defined child as any natural, adopted, step or foster child, the coverage guidance did not define the term. The issue is whether dependency or residency conditions are allowed for …

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New Statute Sheds Light on Three-Day Rule for Hospital Billing

On June 25, 2010, President Barack Obama signed into law the Preservation of Access to Care for Medicare Beneficiaries and Pension Relief Act of 2010. Among other provisions, Section 102 of the legislation broadens the interpretation of what is known as the three-day rule, Medicare's policy for payment for …

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New Rules: Internal Claims and Appeals and External Review Process

The government published rules on July 23 implementing new internal claims and appeals and external review processes under health care reform. The rules, effective for plan or policy years beginning on or after September 23, address new requirements for state external review processes that apply mainly to fully …

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When are annual and lifetime limits allowed?

Recent regulations confirm that the general prohibition on annual and lifetime limits applies only to "essential health benefits." That is, annual and lifetime limits are permissible for "non-essential" health benefits. In addition, for plan years beginning before January 1, 2014, group health plans may establish …

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What is an “essential health benefit”?

The health care reform statute provides that "essential health benefits" must be defined to include the following categories of services: Ambulatory patient services; Emergency services; Hospitalization; Maternity and newborn care; Mental health and substance use disorder services, including behavioral …

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I hear that beginning in 2011, the value of group health plan benefits has to be reported on Form W-2. Does this mean the benefits are taxable?

No.  While it is true that employers must begin reporting the value of certain group health plan benefits on employees’ Form W-2 wage reports beginning in 2011, the benefits are NOT currently subject to taxation.  For now, the government has stated that these benefits are being reported for informational …

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