Tag Archives: Regs and guidance

Regulatory roundup

More healthcare-related regulatory news for plan sponsors, including links to detailed information.

New draft Form 1094-1095 information returns published
The Internal Revenue Service (IRS) has released draft 2017 versions of Form 1094/1095 information returns. The draft instructions for the forms have not been released.

Draft Form 1094-B – Transmittal of Health Coverage Information Returns
Draft Form 1095-B – Health Coverage
Draft Form 1094-C – Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
Draft Form 1095-C – Employer-Provided Health Insurance Offer and Coverage

Forms 1094-B and 1095-B are used by coverage providers to report health plan enrollment as required by Code § 6055. Forms 1094-C and 1095-C are used by applicable large employers (ALEs) to report information relevant to Code § 4980H employer shared responsibility penalties as required by Code § 6056.

How the Medicare Advantage 2018 RxHCC risk score model update impacts plan risk scores

The Centers for Medicare and Medicaid Services finalized a Part D risk score model for payment year 2018. How does this model update affect plan risk scores? This paper by Milliman consultants Adrian Clark and David Koenig summarizes the changes in member risk scores that are due to the RxHCC risk score model update.

Regulatory roundup

More healthcare-related regulatory news for plan sponsors, including links to detailed information.

CMS chief actuary releases memo on the financial effects related to the American Health Care Act
A new memorandum from the Centers for Medicare and Medicaid Services (CMS) summarizes the Office of the Actuary’s estimates of the financial and coverage effects through 2026 of selected provisions of the American Health Care Act (AHCA) of 2017 (H.R. 1628).

To read the entire memo, click here.

DOL releases information regarding mental health parity
The U.S. Department of Labor (DOL) released the following documents related to mental health parity:

Frequently Asked Questions
Draft of Mental Health Parity Disclosure Statement
Request for Information (RIF)

IRS announces HSA and HDHP adjusted limits for 2018

The Internal Revenue Service (IRS) recently published Revenue Procedure 2017-37, which provides the inflation-adjusted amounts for health savings accounts (HSAs) for calendar year 2018. The updated limits specify the maximum annual contributions to HSAs that may be tax-deductible, as well as the minimum deductibles and the maximum out-of-pocket expenses allowed under qualifying high-deductible health plans (HDHPs).

The table below reflects the 2018 and 2017 values:

The “catch-up” contribution amount of $1,000 for individuals aged 55 or older was set by law and has not changed since 2009.

Annual out-of-pocket expenses include the HDHP’s deductibles, copayments, and coinsurance, but not premiums paid by plan participants.

Employers that sponsor HSAs and HDHPs should review their programs and communications materials and plan for the updated limits for 2018.

For additional information about the 2018 updated HSA and HDHP limits, please contact your Milliman consultant.

Regulatory roundup

More healthcare-related regulatory news for plan sponsors, including links to detailed information.

Technical guidance for self-insured health plans on federal external review process
The U.S. Department of Health and Human Services issued “Technical Guidance – Standards for Self-Insured Non-Federal Governmental Health Plans and Health Insurance Issuers Offering Group and Individual Coverage.” This release replaces the technical guidance issued June 22, 2011, with standards adopted in the final regulation at 76 FR 37208 that further define requirements under Public Health Service Act (PHS Act) section 2719(b)(1).

For more information, click here.

Agencies issue ACA FAQs, Part 37
The U.S. Departments of Treasury, Labor (DoL), and Health and Human Services released frequently asked questions (FAQs) Part 37 regarding Patient Protection and Affordable Care Act (ACA) implementation. The FAQs highlight: health reimbursement arrangements (HRAs); integration of HRAs with group health plans sponsored by the employer of a spouse of an employee; Code Section 162(m)(6); and more.

To read the FAQs, click here.

DoL issues FY 2016 MHPAEA enforcement fact sheet
The Employee Benefits Security Administration (EBSA) enforces the law governing 2.2 million private employment-based group health plans, which cover 130.8 million participants and beneficiaries. EBSA relies on its 460 investigators to review plans for compliance with ERISA, including the Mental Health Parity and Addiction Equity Act (MHPAEA). EBSA released its first annual MHPAEA enforcement fact sheet, summarizing its enforcement activity in fiscal year (FY) 2015.

To read the fact sheet, click here.

Regulatory roundup

More healthcare-related regulatory news for plan sponsors, including links to detailed information.

IRS updates Q&As about ACA information reporting
The Internal Revenue Service (IRS) has updated the following three question and answer (Q&A) documents regarding Patient Protection and Accountable Care Act (ACA) information reporting by employers.

Q&A about Information Reporting by Employers on Form 1094-C and Form 1095-C

Q&A on Reporting of Offers of Health Insurance Coverage by Employers (Section 6056)

Q&A on Employer Shared Responsibility Provisions Under the Affordable Care Act

Employers and coverage providers: 11 facts about healthcare information forms
Under the ACA, businesses that provide health insurance to their employees must submit information returns to the IRS and individuals reporting on health coverage. Taxpayers can use the information on these forms when they file their tax returns to verify the months that they had minimum essential coverage and determine if they satisfied the individual shared responsibility provision of the healthcare law. The IRS will use the information on the statements to verify the months of the individual’s coverage. The IRS’s “Health Care Tax Tip 2016-82” provides some information about these information return forms, the purpose of each, and noteworthy dates.

For more information, click here.