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How Healthcare Transparency Can Reduce Costs and Improve Quality
August 20, 2015 in GA
(Worldwide Employee Benefits Network [WEB] - Atlanta Chapter)

Custom Target-Date Strategies
September 10, 2015 in IL
(Pensions & Investments)

Custom Target-Date Strategies
September 17, 2015 in NY
(Pensions & Investments)

2015 Large Employer Reporting Seminar
September 24, 2015 in VA
(TFA Benefits)

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Text of CMS Submission to OMB: Information Collection for Transparency in Coverage Reporting by Qualified Health Plan Issuers
"This proposed collection sets forth the first phase of implementing the transparency requirements established under section 1311(e)(3) of the Affordable Care Act.... CMS intends to first require QHP issuers in the Federally-facilitated Marketplaces (FFMs) and those state-based Marketplaces (SBMs) that use the federal information technology (IT) platform, more commonly known as HealthCare.gov, to report on transparency. These transparency requirements will be phased in for other QHP issuers in a subsequent PRA package.... CMS seeks feedback on the information we will display, as follows: [1] Claims payment policies and practices.... [2] Periodic financial disclosures.... [3] Data on enrollment.... [4] Data on rating practices.... [5] Information on cost-sharing and payments for out-of-network coverage.... [6] Information on enrollee rights under Title I of the Affordable Care Act.... [7] Other information as determined appropriate by the Secretary." [Downloadable ZIP file includes Supporting Statement and descriptions of Data Collection and Display elements to be provided by issuers.] (Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS])

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Text of CMS Reinsurance (RI) and Risk Adjustment (RA) Data Reporting Milestones for the 2015 Benefit Year
"This schedule provides an overview of the major risk adjustment and reinsurance reporting deadlines for the 2015 benefit year.... CMS will use issuers' self-reported baseline data to assess the completeness of issuers' risk adjustment and reinsurance data submissions on their EDGE server. This schedule also provides the dates when CMS anticipates running file processing and payment calculation reports." (Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS])

Text of CCIIO FAQ: Risk Corridors and Medical Loss Ratio (MLR) Resubmissions for the 2014 Benefit Year (PDF)
Unnumbered document, dated August 14, 2015. "After posting the June 30 report, CMS notified some issuers of updates to their risk adjustment transfers and risk adjustment default charge allocations ... [and] stated that issuers must resubmit their 2014 risk corridors and MLR reports.... If the inclusion of an issuer's adjusted risk adjustment amount results in a $25 or less difference in their risk corridors or MLR amount in a given state and market, we will not require the issuer to resubmit the risk corridors and MLR reports for the 2014 benefit year for that state and market. If an issuer is under this threshold and does not resubmit for 2014, this adjusted amount must be included and reflected in its 2015 risk corridors and MLR filings." (Center for Consumer Information and Insurance Oversight [CCIIO], Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS])

Text of CCIIO FAQ: Effect of Uncollected Risk Adjustment Charges (PDF)
Unnumbered document, dated August 14, 2015. "To the extent CMS is not able to fully collect 2014 benefit year risk adjustment charges in a risk pool in a market in a state, 2014 benefit year risk adjustment payments for that risk pool will be adjusted on a pro rata basis to reflect the undercollection. Risk adjustment charges for other issuers in the risk pool would not be affected. If CMS is unable to collect full risk adjustment charges in a state and market, the issuer can reflect this reduction in payment on the following year's risk corridors and medical loss ratio (MLR) filing." (Center for Consumer Information and Insurance Oversight [CCIIO], Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS])

Essential Health Benefits Overview
"[This article] offers an EHB overview in anticipation of HHS' posting of the benchmark plan list and public comment period.... This publication focuses on EHBs as they apply to the private market. The EHB requirement applies to non-grandfathered health plans offered in the individual and small group markets (both inside and outside the Marketplace). Self-insured group health plans, large group market plans, and grandfathered health plans are not required to provide EHBs." (National Health Law Program [NHeLP])

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IRS Releases Draft Instructions for 2015 Forms 1094 and 1095, and Draft Publication About Substitute Forms
"Comments may be submitted on the drafts -- but with no comment period specified, and the filing dates looming, we expect the IRS will be working quickly -- word on the street is that final 2015 forms might be out within a month!" (Thomson Reuters / EBIA)

IRS Seeks More Input on the Cadillac Tax (PDF)
"The employer is expected to calculate the amount of the excess benefit subject to the excise tax and notify the coverage provider and the IRS of the excess benefit. The calculation is based on the 'taxable period' meaning the calendar year. The coverage provider pays the tax.... The how and when of paying the tax is unknown at the present time.... The calculations will require aspirin for you are bound to suffer headaches." (ERISAdiagnostics, Inc.)

Agencies to Propose Transparency Reporting Requirements for Group Health Plans and Insurers
"[ FAQ XXVIII ] indicates that separate rules will be issued for non-QHP coverage and that the requirements may differ, taking into account differences in markets, reporting requirements already in existence for non-QHPs (including group health plans), and other relevant factors. The FAQ also notes the agencies' intent to streamline reporting under multiple reporting provisions and to reduce unnecessary duplication." (Thomson Reuters / EBIA)

Reports of the Death of Employer-Sponsored Health Insurance Are Greatly Exaggerated
"[As] of late 2014, very few companies had moved to drop or narrow health coverage. The shifts from ESHI to public exchanges that have occurred have been concentrated among smaller businesses and early retirees. The economic incentive for dropping ESHI is much stronger for companies whose average wage is low." (Forbes)

Dental Benefits Could Take the Bite Out of the Cadillac Tax
"Employers in the West offer more generous dental benefits. They are more likely to coverage adult orthodontia (51%, compared to 34% in the Northeast) and implants (66%, compared to 59% in the Northeast). Fewer require a deductible for restorative care. And while the benefits are richer, the employee contribution requirements are lower.... Dental benefits are well utilized and highly valued -- but the cost of freestanding dental plan doesn't count toward the excise tax cost threshold. If you have to cut back on the medical benefit, considering sweetening the dental benefit." (Mercer/Signal)

How to Prevent Data Breaches by Service Providers
"Here are some practical ways for organizations -- not just those in healthcare -- to improve data security efforts by service providers: Conduct a comprehensive inventory of all service providers ... Determine which ones pose the greatest risk ... Vet all service providers and be ready to switch if problems arise ... Carefully review all contracts ... Demand an annual risk analysis ... Thoroughly document all the above activities." (Clearwater Compliance)

HHS OIG Finds Most Health Insurance CO-OPs Are Losing Money
"Most federal insurance cooperatives created under the Affordable Care Act are losing money and could have difficulty repaying millions of dollars in federal loans, an internal government audit has found, prompting the Obama administration to step up supervision of the carriers.... [T]he inspector general at [HHS], said that most of the insurance co-ops enrolled fewer people than they had predicted, and that 22 of the 23 co-ops lost money last year." (The New York Times; subscription may be required)

When Does ERISA Apply to Working Owners of Small Companies? Federal District Court Opinion Provides Guidance
"ERISA may apply based on who owns the business.... '[A] plan covering only corporate shareholders was exempt from ERISA only if the company was wholly owned by one shareholder or by the shareholder and his or her spouse.' ... Since Silverman owned the company with two others, he 'is considered an employee under ERISA and his plan is an ERISA plan. Additionally, [Silverman] also was paid a salary and hired by the corporation, further supporting his treatment as an employee for ERISA purposes.' " [ Silverman v. Unum Group , No. 14-CV-6439 (S.D.N.Y. July 30, 2015)] (Lane Powell PC)

SEC Issues CEO Pay Ratio Final Rule
"Despite the SEC's adoption of the final rule, the debate has begun in earnest as to whether companies will in fact ever actually be required to disclose their Pay Ratios.... We do not believe the Final Rule will quell this criticism. We anticipate that the Final Rule will be subject to the following two-prong attack: ... [1] one or more business organizations (or business entities) may sue the SEC to prohibit the implementation of the Final Rule on the grounds that the SEC failed to adequately assess the economic effects of the Final Rule.... [2] if Republicans should gain control of the White House in 2016 and maintain control of Congress, the outright repeal of the Dodd-Frank mandate would likely increase." (Meridian Compensation Partners, LLC)

Call for Proposals - Present at the 2016 National Wellness Conference National Wellness Institute

ICMA-RC?s Enhanced, Industry-Leading Mobile App Expands Retirement Planning Capabilities for Participants ICMA-RC

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