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11/17 CMS Extends Reinsurance Fee Deadline; Payment Deadline Unchanged
CMS has extended the deadline for contributing entities to submit 2014 enrollment counts for the reinsurance fee. The new deadline is December 5, 2014. Payment deadlines remain at January 15, 2015 and November 15, 2015. For more information about the reinsurance fee and how to calculate, please refer to our 2013 Alert on this topic.
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11/7 New Guidance Confirms Employer Payment of Employee Premiums for Individual Plans is not Permitted under ACA
Newly released FAQs from the DOL, HHS and the Treasury effectively prohibit employers from paying for individual coverage or incentivizing sick employees to enroll in Exchange coverage. The guidance confirms that employer payment or reimbursement of employee premiums for individual plans is not permitted under the rules, regardless of whether the payments are made on a pre-tax or post-tax basis.
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11/4 Compliance Updates: HPID Delay, FSA Max Increase, Reinsurance Reminder
On a much welcomed note, CMS has delayed the HPID requirement indefinitely. The IRS announced an increase in the maximum employee election from $2,500 to $2,550 for 2015 plan years. Lastly, the deadline to upload data and arrange to make Transitional Reinsurance Fee payment is less than two weeks away (November 17) for self-funded major medical plans.
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10/31 EEOC Suit Alleges Commonplace Wellness Program Violates ADA, GINA
The Equal Employment Opportunity Commission (EEOC) filed its third petition against an employer this year. This most recent suit seeks to prevent Honeywell, Inc. from implementing what appears to be a very common wellness program design. Although it appears that Honeywell’s wellness program complies with the final wellness regulations under HIPAA and ACA, the petition alleges ADA and GINA violations. Read our Alert evaluating whether this suit creates cause for concern for employers sponsoring ACA compliant wellness programs.
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