With 2013 right around the corner, one new requirement that will be in effect on January 1 for calendar-year non-grandfathered group health plans is the coverage of certain women’s preventive services without cost-sharing. The coverage requirement is effective for plan years beginning on or after August 1, …
Summary of Benefits and Coverage Now in Effect
October 1, 2012 Leave a Comment
With fall open enrollment season upon us, group health plan sponsors should remember that the new Summary of Benefits and Coverage (“SBC”) requirements are now in effect. The first SBC must be provided to participants and beneficiaries for enrollment or re-enrollment periods beginning on or after September …
District Court Holds That Michigan Tax on Benefit Payments is Not Preempted By ERISA
September 11, 2012 Leave a Comment
We previously addressed the passage of Michigan’s Health Insurance Paid Claims Assessment Act (“Act”), which imposes a 1% tax on claims paid by health insurance carriers, and the subsequent legal challenge to that law by the Self-Insurance Institute of America (“SIIA”) in SIIA v. Snyder. On August 31, …
Guidance on 90-day Waiting Periods for Group Health Plans
September 10, 2012 Leave a Comment
For plan years beginning after December 31, 2013, PPACA generally prohibits both grandfathered and non-grandfathered group health plans from imposing waiting periods greater than 90 days. The IRS[1] recently released Notice 2012-59 (the “Notice”), which provides guidance about new limitations on the maximum …
New Guidance on Measuring Full-Time Employee Status
September 4, 2012 1 Comment
Newly released IRS Notice 2012-58 describes the voluntary safe harbors that employers may use to identify full-time employees for purposes of the employer mandate. Employers who employ 50 full-time and full-time equivalent employees are subject to the mandate, and the number of full-time employees determines the …
Fee Disclosure for Welfare Plans
August 23, 2012 Leave a Comment
What’s hot in benefits this summer? Fee disclosures – fee disclosures by providers to employers and fee disclosures by employers to participants. You may have seen some of the recent buzz about fee disclosure, but does fee disclosure apply to welfare plans? No, not yet. Generally, the fee disclosures …