Compliance and Legal Department

Legal Alert: IRS Issues Affordability Percentage Adjustment for 2020

By Stacy Barrow - July 24, 2019

The Internal Revenue Service (IRS) has released Rev. Proc. 2019-29, which contains the inflation adjusted amounts for 2020 used to determine whether employer-sponsored coverage is “affordable” for purposes of the Affordable Care Act’s (ACA) employer shared responsibility provisions and premium tax credit program. As shown in the table below, for plan years beginning in 2020, [Read More]

Legal Alert: IRS Expands HSA Preventive Care Safe Harbor to Include Chronic Conditions

By Stacy Barrow - July 18, 2019

On July 17, 2019, the Internal Revenue Service (IRS) released Notice 2019-45, which expands the definition of preventive care benefits that can be provided by a high deductible health plan (HDHP) to include certain chronic conditions.  The guidance in the Notice may be relied upon immediately.  In general, most HDHP participants may establish and contribute [Read More]

Legal Alert: President Trump Issues Executive Order Encouraging Transparency in Pricing and Expanding Consumer-Directed Arrangements

By Stacy Barrow - June 28, 2019

On June 24, 2019, President Trump issued an Executive Order intending to develop price and quality transparency initiatives to ensure that healthcare patients can make well-informed decisions about their care. This is part of the consumer-driven healthcare initiative, which has been a focus of government and patient groups alike to have more transparency regarding the [Read More]

Legal Alert: Final Rule Released on Individual Coverage and Excepted Benefit HRAs

By Stacy Barrow - June 14, 2019

On June 13, 2019 the Department of Labor, the Department of Health and Human Services, and the Treasury Department (the “Departments”) released the final rule concerning health reimbursement arrangements (HRA) for individual market coverage and excepted health benefits. The rule, based on an executive order from President Trump in 2017, is intended to increase choice [Read More]

IRS Releases 2019 HSA Contribution Limits and HDHP Deductible and Out-of-Pocket Limits

In Rev. Proc. 2018-30, the IRS released 2019 HSA Contribution Limits regarding inflation-adjusted amounts for 2019 relevant to HSAs and high deductible health plans (HDHPs).  The table below summarizes those adjustments and other applicable limits. Out-of-Pocket Limits Applicable to Non-Grandfathered Plan The ACA’s out-of-pocket limits for in-network essential health benefits have also been announced and [Read More]

REMINDER: PCORI Fees Due By July 31, 2018

Employers that sponsor self-insured group health plans, including health reimbursement arrangements (HRAs) should keep in mind the upcoming July 31, 2018 deadline for paying fees that fund the Patient-Centered Outcomes Research Institute (PCORI).  As background, the PCORI was established as part of the Affordable Care Act (ACA) to conduct research to evaluate the effectiveness of [Read More]