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Straight From The Source Blog


Reinsurance fee counts due November 15

October 25 , 2016

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The ACA requires health insurance issuers (insurance carriers) and self-funded group health plans to fund a transitional reinsurance program that will be in place from 2014 through 2016. Reinsurance fees are collected by the Department of Health and Human Services (HHS) for each health plan that meets minimum value. The fees are based on your enrollment count for the first nine months of the calendar year, and this count only needs to be submitted once per year by November 15.

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Tags: Health Care Reform


Final forms for ACA reporting released

October 04 , 2016

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The IRS has released final 2016 forms and instructions for reporting under Internal Revenue Code Sections 6055 and 6056.

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Tags: Health Care Reform


Medicare Part D notices due October 15

September 27 , 2016

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The deadline to distribute creditable coverage disclosure notices to Medicare-eligible individuals is only a few weeks away. If you have any plan participants eligible for Medicare Part D, you must disclose to those individuals before October 15 each year whether their prescription coverage through your group plan is as comprehensive as the benefits offered under Medicare Part D.

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Tags: Health Care Reform


Time to start thinking about 2016 ACA reporting

August 29 , 2016

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Just as you're recovering from the first round of ACA employer reporting, it’s time to start thinking about gathering the data necessary to fill out your 2016 1095-Cs in 2017. To help keep you on your toes, the IRS has already released draft forms and instructions for 2016 reporting under Sections 6055 and 6056.

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Tags: Health Care Reform


PCORI fees due August 1, 2016

July 05 , 2016

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With August 1 on the horizon, some employers will need to file an IRS Form 720 and submit the applicable payment for their Patient Centered Outcomes Research Institute (PCORI) fees. Employers with self-funded health plans and those with HRAs are generally responsible for filing and paying the fee. Employers with fully-insured health plans are generally not responsible for the filing or paying, unless they also sponsor an HRA.

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Tags: Health Care Reform


ACA electronic reporting due June 30

June 27 , 2016

Health Care Reform Update

Here’s one last reminder of the approaching deadline for IRS electronic reporting under the ACA until next year. Filing the 2015 Forms 1094-B, 1095-B, 1094-C and 1095-C with the IRS must be completed no later than June 30, 2016. Please be aware that these forms cannot simply be uploaded to the IRS website as a pdf or similar file format. You must have a system that is compatible with the IRS Filing Information Returns Electronically (FIRE) system, which is part of the Affordable Care Act Information Returns (AIR) program.

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Tags: Health Care Reform


The latest in health care compliance: The subsidy crackdown

June 22 , 2016

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PPACA. ERISA. HIPAA. COBRA. EEOC. FLSA. FMLA. It’s a complex alphabet soup of agencies and laws that employers have to deal with today to offer health care benefits to their employees. What do they all have in common? Compliance requirements. And the Department of Labor (DOL) and the IRS have beefed up their enforcement activities in recent years.

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Tags: Health Care Reform, Employee Benefits


COBRA: Still relevant after all these years

April 20 , 2016

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Since the passage of the Affordable Care Act (ACA), we’ve seen a whirlwind of change in the health care and health insurance landscape here in the U.S., ushering in a whole new era of options and regulatory issues for both employers and employees.

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Tags: Health Care Reform, Employee Benefits


Reminder of 2016 ACA reporting deadlines

March 30 , 2016

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As a reminder, the due dates for IRS reporting under the ACA are as follows: Forms 1095-B and 1095-C must be furnished to individuals no later than March 31, 2016. Filing the 2015 Forms 1094-B, 1095-B, 1094-C and 1095-C with the IRS must be completed no later than May 31, 2016, if not filing electronically, and June 30, 2016, if filing electronically. 

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Tags: Health Care Reform


Medicare Part D disclosure notices for calendar year plans due by February 29

February 16 , 2016

Higginbotham Health Care Reform Update

Entities that provide prescription drug coverage to Medicare Part D eligible individuals must disclose to the Centers for Medicare & Medicaid Services (CMS) whether the coverage is "creditable prescription drug coverage." This disclosure is required whether the entity's coverage is primary or secondary to Medicare. Entities must disclose creditable coverage status to CMS using the online Disclosure to CMS Form found here. The disclosure should be completed annually no later than 60 days from the beginning of a plan year (contract year/renewal year), within 30 days after termination of a prescription drug plan, or within 30 days after any change in creditable coverage status.

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Tags: Health Care Reform


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