Author Archives: NAHU

By Megan Diehl, Manager of Compliance Consulting, MZQ Consulting The Patient-Centered Outcomes Research Institute (PCORI) fee established by the Affordable Care Act helps fund research to evaluate and compare health outcomes, clinical effectiveness, risks, and benefits of medical treatment and services.  The fee is currently in place through 2029.  In Notice 2023-70, the IRS announcedContinue reading “2023-2024 PCORI Fee Released”

By Megan Diehl, director of compliance consulting, MZQ Consulting The Internal Revenue Service (IRS) recently released draft instructions for preparing, distributing, and filing 2023 Forms 1094-B/C and 1095-B/C. These instructions largely mirror guidance the IRS has published in previous years, except that the electronic filing threshold has been reduced from 250 forms to ten formsContinue reading “Electronic Filing Threshold Reduced in Draft 2023 Form 1094 and 1095 Instructions”

By Lee Spiegel, Compliance Director, MZQ Consulting By October 13, 2023, plan sponsors that offer prescription drug coverage must provide notices of creditable or non-creditable coverage to Medicare-eligible individuals.  While plan sponsors are typically responsible for providing these notices by October 14th every year, this year’s notice is due by October 13th because the 14thContinue reading “Deadline Approaching for Medicare Part D Creditable Coverage Notices”

By: Megan Diehl, Manager of Compliance Consulting, MZQ Consulting Many sponsors of fully insured health plans either already have or will soon receive checks from their insurance carriers, along with a notice informing them that the review is a medical loss ratio (MLR) rebate.  Plan sponsors should receive these checks by September 30, 2023.  TheContinue reading “Guidelines for Processing Medical Loss Ratio Rebates”

By: David Mordo, Senior Compliance Consultant, MZQ Consulting The IRS recently released Revenue Procedure 2023-29, which declared that the Affordable Care Act (ACA) benchmark for determining the affordability of employer-sponsored health coverage will significantly decrease to 8.39% of an employee’s household income for the 2024 plan year.  This almost three-quarters of a percentage point isContinue reading “ACA Affordability Percentage Drops to a New Low for 2024”

By: David Mordo, Senior Compliance Consultant, MZQ Consulting With the ongoing issue of Medicaid redetermination taking place across the nation, the Centers for Medicare & Medicaid Services (CMS), the Treasury, and the Department of Labor (collectively, the Agencies) are strongly encouraging group health plan sponsors to extend special enrollment periods for individuals who are losingContinue reading “Agencies Call on Group Health Plan Sponsors to Extend Special Enrollment Period for Medicaid Redeterminations”

By Jessica Waltman Late last week, the Departments of Health and Human Services, Labor, and Treasury (the Departments) published a set of FAQs that clarify how certain surprise billing protections interact with the Affordable Care Act’s (ACA) maximum out-of-pocket limit (OOP) requirements.  The FAQs also clarify whether facility fees are subject to specific transparency inContinue reading “New Guidance Issued on Surprise Billing, Out-of-Pocket Limits, and Facility Fees”

By: Megan Diehl, MZQ Consulting Late last week, the IRS published additional guidance modifying the COVID-19 coverage that high deductible health plans (HDHPs) can provide while maintaining their HSA-qualified status. This notice was provided in response to the end of the COVID-19 Public Health Emergency (PHE) and National Emergency Period. HSA participants can only contributeContinue reading “IRS Publishes Additional Guidance for HDHPs on COVID-19 Preventive Care”

By: Jennifer Berman, CEO, MZQ Consulting Over the past several years, the employer-plan marketplace has seen a rise in “fixed-indemnity wellness policies,” which promise to help both employers and employees save on income and employment taxes.  Under these arrangements, employees elect to defer cash on a pre-tax basis through a Section 125 cafeteria plan andContinue reading “IRS Confirms Certain “Wellness” Programs Cannot Be Used to Avoid Taxation”

By Jessica Waltman, Principal, Forward Health Consulting The federal Section 125 “cafeteria plan” regulations permit health plans to reimburse participants for qualifying medical and dependent care expenses on a pre-tax basis through health flexible spending accounts (FSAs) and dependent care assistance plans (DCAPs) if those claims are properly and fully substantiated.  If claims are improperlyContinue reading “IRS Reminds Plan Sponsors of Cafeteria Plan Claims Substantiation Requirements”