Pension Plan Administrator
Panagiotu Pension Advisors
in WA

Client Relationship Manager
M Financial Group
in OR

Manager of Employee Benefit Services
AGH
in KS

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Fringe Benefit Planning After Tax Reform
August 9, 2018 WEBCAST
Eli Financial

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Text of Draft 2018 IRS Form 1095-A: Health Insurance Marketplace Statement (PDF)

"This Form 1095-A provides information you need to complete Form 8962, Premium Tax Credit (PTC). You must complete Form 8962 and file it with your tax return (Form 1040 or Form 1040NR) if any amount other than zero is shown in Part III, column C, of this Form 1095-A (meaning that you received premium assistance through advance credit payments) or if you want to take the premium tax credit." Internal Revenue Service [IRS]

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Text of CSR Reconciliation Discrepancy FAQ: Submission of Additional Claims for 2017 Benefit Jear After June 1 (PDF)

"Can an issuer file a cost-sharing reduction (CSR) reconciliation discrepancy to submit additional 2017 benefit year claims that it was unable to submit by the June 1, 2018 CSR reconciliation data submission deadline? Answer: Yes[.]" Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS]

Text of CMS Memo: 2017 Risk Adjustment (RA) Final Rule -- Resumption of RA Operations (PDF)

3 pages. Unnumbered document, July 27, 2018. "This document provides updated guidance as to the operation of the HHS-operated risk adjustment program for the 2017 benefit year.... [1] Collection of 2017 benefit year risk adjustment charges ... [2] Distribution of 2017 benefit year risk adjustment payments ... [3] 2017 benefit year EDGE/risk adjustment discrepancies ... [4] 2017 benefit year risk adjustment administrative appeals ... [5] Medical Loss Ratio (MLR) Reporting." Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS]

Text of 2019 Updated Final HHS Risk Adjustment Model Coefficients (PDF)

19 pages. Unnumbered document, July 27, 2018. "[CMS] previously released updated 2019 benefit year final coefficients to address a few technical errors in the adult risk adjustment model coefficients and the infant risk adjustment model coefficients that were identified after publication of the final rule.... [T]his document announces a further update to the 2019 benefit year final risk adjustment model coefficients (or factors) to reflect an additional recalibration related to an update to the 2016 enrollee-level EDGE dataset[.]" [Also available in XLSX format .]
Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS]

Self-Funded ERISA Health Plans May Opt Into New Law Regarding Out-of-Network Service Providers

"The NJ Act [provides for]: [1] A limitation on payments by a patient who receives emergency/urgent care services, or inadvertent out-of-network services, to the in-network cost-sharing for such services (whereby the remaining provider fees may be billed to the health benefit plan); [2] Certain binding arbitration procedures ... [3] Automatic assignment to the healthcare provider of any benefits payable by the patient's health benefit plan for emergency/urgent care services or inadvertent out-of-network services; [4] A prohibition on the waiver or rebate by an out-of-network healthcare provider of any deductible, copayment, or coinsurance owed by the patient under the terms of his health benefit plan as an inducement for such patient to seek healthcare services from that provider." Haynes and Boone CDG, LLP, via Lexology

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Third Circuit Finds Anti-Assignment Provision Does Not Prevent the Grant of Power of Attorney

"Noting that other jurisdictions have upheld anti-assignment clauses, the Third Circuit agreed that the plan's anti-assignment clause was valid. However, it noted that assignments and powers of attorney differ in important aspects An assignment transfers ownership of a claim to the provider, giving it standing to assert those rights and to sue on its own behalf. A power of attorney, on the other hand, does not transfer an ownership interest in the claim." [ American Orthopedic & Sports Medicine vs. Independence Blue Cross Blue Shield , No. 17-1663 (3d Cir. May 16, 2018)]
The Wagner Law Group

Are Health Care Services Shoppable? Evidence from the Consumption of Lower-Limb MRI Scans

"Fewer than 1 percent of individuals used a price transparency tool to search for the price of their services in advance of care. The choice of provider is such that, on average, individuals bypassed 6 lower-priced providers between their home and the location where they received their scan.... The influence of referring physicians is dramatically greater than the effect of patient cost-sharing." National Bureau of Economic Research [NBER]; purchase required for full document

Shopping for Health Care Simply Doesn't Work. So What Might?

"A body of research ... shows that people do in fact cut back on care when they have to spend more for it. The problem is that they don't cut only wasteful care. They also forgo the necessary kind.... Though patients seem to follow the advice of their doctors on where to go, their doctors don't have all the information on hand to make the best decisions for the patient either.... What seems likelier to work is doing more to influence what doctors advise." The New York Times; subscription may be required

Will an Increase in HSA Limits Prompt Additional Contributions? (PDF)

"[EBRI] has found that only 13 percent of account owners contributed the maximum in 2016. This, despite the fact that contributions to an HSA benefit from a triple-tax advantage ... EBRI's research also reveals that account holders who held their HSAs for a longer period of time tended to contribute more." Employee Benefit Research Institute [EBRI]

Market Concentration Variation of Health Care Providers and Health Insurers in the United States

"[F]or insurers, almost all the MSAs fell into the middle categories, either being highly concentrated MSAs (54.5%) or moderately concentrated (36.9%).... Provider concentration was in a higher category relative to insurers in 58.4 percent of the MSAs, while the opposite was true in only 5.8 percent of the MSAs." The Commonwealth Fund

House Committee Letter to FTC Requesting Review of Merger of Pharmacy Benefit Managers (PDF)

"Consolidation in the PBM industry is part of a larger trend of consolidation in the health care market more generally. PBMs play a significant role in the health care market and are likely to influence health care costs.... PBMs have used their market power to try to increase their profits and that PBMs have encouraged higher list prices for prescription drugs that increase co-pays for patients. Because some mergers may benefit patients while other mergers may harm patients, we believe it is important to closely monitor these trends." Energy and Commerce Committee, U.S. House of Representatives

Factors That Will Determine the Damage From Association Health Plans

"How much will AHPs proliferate? ... How aggressively will AHPs try to avoid sicker enrollees? ... What will states do to protect consumers?" Center on Budget and Policy Priorities

Calculation of PCORI Fees; HRA Terminated Mid-Year

Plan year runs 1/1/17- 12/31/17. HRA is terminated 4/30/17. Must a Form 720 be done? Are fees based on the period 1/1/17 through 4/30/17? BenefitsLink Message Boards

SAR Not Required for Unfunded Plan?

We have several health and welfare plans that are unfunded (benefits paid solely from general assets with the exception of employee contributions). We have one attorney who says a SAR is not required, due to Technical Release 92-01 -- i.e., that employee contributions paid to the carrier within 3 months are not plan assets. Another attorney disagrees, and says that despite Technical Release 92-01 the SAR is required because it's not funded 100% from general assets. I have not heard back from the DOL's Office of Regulations and Interpretations. What do you think? BenefitsLink Message Boards

New HRA; No Participants in 2017; Form 5500 Required?

Client instituted retiree HRA effective Jan. 1, 2017. The plan has no participants and no contributions/assets in the plan. Is a Form 5500 required? Do I simply file a Form 5500-SF with zeros for participants, assets, liabilities, etc.? BenefitsLink Message Boards

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Press Releases

Lockton Ranks on Top 10 List of Largest Brokers in the World Lockton

Publisher of Book with "Official SSA Answers" on Retirement Agrees to $22,500 Penalty Office of the Inspector General [OIG], U.S. Social Security Administration [SSA]

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