“To Fee or Not to Fee” — Considerations and Concerns

Brokers have been buffeted by the myriad changes occurring at record pace over these past few years. The Affordable Care Act (ACA) has had a dramatic impact on the types of health insurance products available, the scope of benefits offered and how brokers are compensated for the valuable services they provide. Many brokers have transformedContinue reading ““To Fee or Not to Fee” — Considerations and Concerns”

Business Associates Beware – A Fine May Find You

HIPAA’s privacy and security requirements have been a part of the health insurance and insurance broker lexicon for many years. Most health insurance brokers have signed at least one – and often multiple – BAAs (Business Associate Agreements) over the course of the years. HIPAA HITECH, enacted into law in 2009 increased the responsibilities forContinue reading “Business Associates Beware – A Fine May Find You”

IRS Publishes 2016 Draft Forms for ACA Reporting

With the first ACA reporting deadlines for employers in the rearview mirror, the IRS has released draft forms for 2016. These drafts, if finalized, will be used when employers file in 2017. The deadlines for reporting of 2016 health coverage are expected to return to the original dates: Deadline to distribute forms to employees andContinue reading “IRS Publishes 2016 Draft Forms for ACA Reporting”

CMS Acts on Documentation for Special Enrollment Periods (SEPs)

In an effort to stabilize the individual insurance marketplaces and improve the risk pool CMS has rolled out a new Special Enrollment Verification process. Individuals who assert that they have qualified for one of five Special Enrollment Periods (SEPs) will be sent a Marketplace Eligibility Determination Notice requesting documentation to support their eligibility for theContinue reading “CMS Acts on Documentation for Special Enrollment Periods (SEPs)”

Correcting Employer Reporting Errors Needed to Meet Good Faith Compliance Standard

As employers were struggling to complete Forms 1095-C to get them in their employees’ hands by March 31, they had the small comfort that the IRS had announced that employers needed to meet a “good faith compliance” standard to avoid penalties. The expectation was that employers would do their best to comply with this newContinue reading “Correcting Employer Reporting Errors Needed to Meet Good Faith Compliance Standard”

Open Up the Silos for Optimum Compliance

With implementation of the ACA, many brokers and employers have had a laser focus on understanding the requirements necessary to comply with the law. And, rightly so! As such, employers have adopted lookback measurement periods, identified variable hour employees, not to mention a myriad of terms and constructs.  Employers who have filed their 1094-C andContinue reading “Open Up the Silos for Optimum Compliance”

Short Term Policies No ACA Panacea

An insurance product that many thought would become extinct with implementation of the ACA can’t be counted out – yet. Short term health insurance policies have been an attractive short-term option for many years. While the policies generally offer limited benefits, the ability to purchase a plan for 30 days or 6 months or evenContinue reading “Short Term Policies No ACA Panacea”

Employer Reporting When Employee Waives Coverage

Many employers are struggling with the ACA’s employer reporting requirements. It’s hard enough to know what to report when an employee enrolls in coverage. But, what is the proper way to report that an employee has waived coverage? Line 16 becomes very important in this scenario. If the employer has adopted an affordability safe harbor,Continue reading “Employer Reporting When Employee Waives Coverage”

Coping with COBRA… and Employer Reporting!

Employer reporting is hard enough! But, employer reporting when there has been a COBRA qualifying event revives images of coiled snakes striking out. Final 2015 instructions for completing forms 1094-C and 1095-C changed some of the rules related to reporting COBRA offers of coverage. Example for Termination at end of month  Facts or Assumptions: EmployerContinue reading “Coping with COBRA… and Employer Reporting!”